CBDT signs 10 unilateral APAs with taxpayers

The Central Board of Direct Taxes (CBDT) on 28 February 2017 signed ten Advance Pricing Agreements (APAs) with taxpayers. The APAs were signed in various sectors of the economy like Telecom, Pharmaceutical, Banking & Finance, Steel, Retail and Information Technology, etc.

In the current financial year, a total of 76 APAs (7 Bilateral APAs and 61 Unilateral APAs) have already been signed by CBDT.

With this, the total number of APAs entered into by the CBDT reached 140 in number. This includes 10 Bilateral APAs and 130 Unilateral APAs. The CBDT expects more APAs to be signed before the end of the current fiscal.

Key Highlights
• Two of these ten agreements are Bilateral APAs with the United Kingdom and Japan. While, seven of these agreements have rollback provisions in them.
• The APAs entered into over the last week pertain to various sectors of the economy like Telecom, Pharmaceutical, Banking & Finance, Steel, Retail, Information Technology, etc.
• The international transactions covered in these agreements include Payment of Royalty Fee, Trading in Goods, IT Enabled Services, Software Development Services and Marketing Support Services.
• The APAs also cover Clinical Research Services, Non-binding Investment Advisory Services, Payment of Interest on ECB, etc.

About Advance Pricing Agreement (APA) Scheme
• The APA Scheme was introduced in the Income-tax Act, 1961 in 2012 and the Rollback Provisions were introduced in 2014.
• The scheme aims 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 showcased a lot of interest from taxpayers that has resulted in filing of over 700 applications in about five years.
• The progress of the APA Scheme is seen as strengthening the Union Government’s resolve of fostering a non-adversarial tax regime.