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CBDT signs 2 more APAs with taxpayers in September
October, 12th 2017

The Central Board of Direct Taxes (CBDT) today said it has signed two more advance pricing agreements (APAs) in September with Indian taxpayers as it looks to reduce litigation by providing certainty in transfer pricing.

The two APAs signed during September, 2017 pertain to automobile and healthcare consulting sectors.

"With the signing of these two agreements, the total number of APAs entered into by CBDT till date has reached 177. This includes 164 unilateral APAs and 13 bilateral APAs.

"In the current financial year, a total of 25 APAs (2 bilateral and 23 unilateral) have been signed till date," the CBDT said in a statement.

The statement said international transactions covered in these two APAs include provision of IT enabled services, provision of software development services and provision of engineering design services.

It pointed out that APA scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the arm's length price of international transactions in advance for a maximum period of five future years.

Noting that since its inception, the APA scheme has attracted tremendous interest among multi-national enterprises (MNEs), the statement said,"the progress of the APA scheme strengthens the government's commitment of fostering a non- adversarial tax regime."

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