« Top Headlines » Open DEMAT Account in 24 hrs  Delhi HC Rules GST Registration Cannot Be Cancelled Retrospectively Without a Clear Show Cause Notice (SCN)  Belated income tax return AY 2026-27: How to file, late filing charges and what you may lose  Major Financial Changes from August 1, 2026: ITR Deadline, RBI MPC Meeting, Tatkal Ticket Rules & More  Government proposes to ease tax relief conditions for offshore funds  TallyPrime Connected Banking: Automating Banking and Accounting  ITR Filing Deadline 2026: Is July 31 the Last Date to File Your Income Tax Return? Latest Official Update  ITR filing deadline nears: How to file income tax return online on e-filing portal - quick 15-step guide  Will the ITR Filing Deadline Be Extended Beyond July 31 for FY 2025-26? Here's the Latest Update for Taxpayers  Income Tax Refund Delayed for AY 2026-27? 5 Common Reasons Your Refund May Be Stuck and How to Fix It  ITR Filing 2026: FM Nirmala Sitharaman Asks Tax Officials to Let Honest Taxpayers Correct Genuine Mistakes  Will Your FCNR Deposit Stay Tax-Free After Returning to India? Tax Rules Explained for NRIs «  CEOs favour FBT abolition in 08-09 Budget: Assocham survey... Excise Dept meet on e-payment... » Advance pricing could solve tax tiffs November, 27th 2007 A major overhaul of international tax regulations could be on the cards. The government is examining the possibility of introducing advance pricing arrangement (APA) as part of changes in the countrys transfer pricing regulations. A sub-group set up under the international taxation division of the Central Board of Direct Taxes (CBDT) has recommended this. Sources said the suggestions were being examined by the government which feels the time may be ripe for introducing APAs as disputes pertaining to transfer pricing were on the rise and tax authorities had gained technical competence in the last few years. The critical objective is certainty for a taxpayer as opposed to potential litigation which leads to uncertainty. Its like authority for advance ruling under transfer pricing, says KPMG partner Sudhir Kapadia. An APA is an agreement between a taxpayer and the tax authorities which allows both to set out in advance the method of determining transfer pricing for inter-company transactions. Most countries allow APAs under their transfer pricing regulations as these help in resolving actual or potential pricing disputes in a cooperative manner. These also provide an alternative to the traditional dispute-resolution process. Industry and tax experts have been demanding APAs since transfer pricing laws were introduced in the country in 2001. The government should look at a timeframe for conclusion of APAs when it introduces it to make it successful. A relationship based on trust should be established between the taxpayer and the APA authorities. Medium-term bilateral agreement with countries to make APA more effective for multinational company tax payers should also be looked at, Mr Kapadia said, adding that most countries go in for APAs. A review of the threshold limit for selection for transfer pricing audit, pegged at Rs 15 crore at present, could also be on cards. This is because the government wants tax authorities to focus on quality in case of transfer pricing audits. The sub-group has also made recommendations on arms-length methodologies. Some of the changes suggested by the sub-group could be looked at for incorporation in the forthcoming Budget. Transfer pricing refers to the pricing of assets, tangible and intangible, services and funds transferred within an organisation in a cross-border transaction.