CBDT signs four unilateral advance pricing agreements

New Delhi, Nov 23 (IANS) The Central Board of Direct Taxes (CBDT) signed four unilateral Advance Pricing Agreements (APAs) over the last two days pertaining to various sectors like pharmaceuticals, Information Technology and construction, an official said on Wednesday.

“CBDT has entered into four more unilateral APAs on November 22-23, 2016. The international transactions covered in these agreements include software development services, IT enabled services (BPOs), engineering design services, contract R&D services and marketing support services,” the Finance Ministry said in a statement.

With these, the total number of APAs entered into by the CBDT has reached 115. These include seven bilateral APAs and 108 unilateral APAs till date. During the current financial year, a total of 51 APAs (four bilateral APAs and 47 unilateral APAs) have been entered into so far.

“Some of these agreements also have a rollback provision in them,” the statement said.

The APA scheme was introduced in the Income-tax Act in 2012 and the “rollback” provisions were introduced in 2014. The scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and setting the prices of international transactions in advance.

Since its inception, the APA scheme has evinced a lot of interest from taxpayers and that has resulted in more than 700 applications (both unilateral and bilateral) being filed in just four years.

The progress of the APA Scheme strengthens the government’s mission of fostering a non-adversarial tax regime.

“The approach and functioning of the officers in the APA teams have been appreciated and acknowledged by the industry in India and abroad. The CBDT expects more APAs to be concluded and signed in the near future,” the statement added.