Advance Pricing Agreements

  • 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 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.
  • The approach and functioning of the officers in the APA teams have been appreciated and acknowledged by the industry in India and abroad.

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