CBDT signs two unilateral advance pricing agreements

The Central Board of Direct Taxes (CBDT) has entered two unilateral Advance Pricing Agreements (APAs) pertaining software and information technology sectors.

"The CBDT has entered into two Unilateral Advance Pricing Agreements (APA) on May 4, 2017, and May 11, 2017, respectively, with Indian taxpayers. One of the agreements also has 'rollback' provision," the Finance Ministry said in a statement here.


"The two APAs signed pertain to chip design/development of embedded software and Information technology (software development) sectors of the economy," the ministry said.

"The number of APAs signed in the current financial year now is four," it added.

In the last financial year, a total of 76 APAs (seven bilateral APAs and 61 unilateral APAs) were signed.

"The CBDT expects more APAs to be signed in the near future," 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 for the maximum of five future years.

"Further, the taxpayer has the option to roll-back the APA for four preceding years, as a result of which, total nine years of tax certainty is provided," the statement said.

Since its inception, the APA scheme has attracted tremendous interest among multinational companies, the government said.

The progress of the APA scheme fosters a non-adversarial tax regime, it added. #casansaar (Source - IANS, Business Standard)