Indian Advance Pricing Agreement regime moves forward with signing of 18 APAs by CBDT in March, 2019


  • The Central Board of Direct Taxes (CBDT) has entered into 18 APAs in the month of March 2019, which includes 03 Bilateral APAs (BAPAs). With the signing of these APAs, the total number of APAs entered into by the CBDT in the year 2018-19 stands at 52, which includes 11 BAPAs.
  • The total number of APAs entered into by the CBDT as of now stands at 271, which inter alia includes 31 BAPAs.

Key highlights

  • The BAPAs entered into during the month of March 2019 were with the following treaty partners:
    • Australia – 1
    • Netherlands – 1
    • USA – 1
  • The BAPAs and Unilateral APAs (UAPAs) entered into during the month of March 2019 pertain to various sectors and sub-sectors of the economy like anti-friction bearings, risk management solutions platforms, BPO, IT/ITeS, ATMs, industrial and institutional cleaning and hygiene products, etc.
  • The International Transactions covered in all these Agreements, inter alia, include the following, –
    • contract manufacturing
    • provision of software development services
    • back office engineering support service
    • provision of back office (ITeS) support services
    • provision of marketing support services
    • payment of royalty for use of technology and brand
    • trading
    • payment of interest
  • The progress of the APA scheme strengthens the Government’s resolve of fostering a non-adversarial tax regime. The Indian APA programme has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner.


  • APA is an agreement between the taxpayer and the tax authority in which transfer assessment method is determined to determine the cost of international transactions done by the taxpayer in the future.
  • This creates certainty about the tax amount associated with the international transaction made by the taxpayer.

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