Advance pricing agreements (APAs) were introduced in 2012 by the government to provide tax certainty to those multinational corporations that agree to certain principles relating to the valuation of their cross-border transactions.

The Central Board of Direct Taxes (CBDT) on Wednesday said it has entered into five unilateral advance pricing agreements (UAPA) and two bilateral advance pricing agreements (BAPA) in January this year. This includes the first BAPA signed with US, the board said. Advance pricing agreements (APAs) were introduced in 2012 by the government to provide tax certainty to those multinational corporations that agree to certain principles relating to the valuation of their cross-border transactions. The agreements also provide assessees with an alternate dispute-resolution mechanism with respect to transfer pricing. While unilateral pacts involve only the taxpayer and the tax authority of the country where the tax payer is located, bilateral agreements involve the taxpayer, associated enterprise of the taxpayer in the foreign country, the tax authority of the country where the taxpayer is located and the foreign tax authority. “The seven APAs entered into during January 2018 pertain to various sectors of the economy like banking, insurance, investment advisory, information technology, chemicals and engineering,” the board said. With these, the total number of APAs entered into by the CBDT has gone up to 196, which includes 178 UAPAs and 18 BAPAs.