Signing of Bilateral Advance Pricing Agreements (B- APAs)
The CBDT signed 3 bilateral APAs on 18th November, 2016 taking the total number of APAs signed [both- bilateral and unilateral] so far to 111. These agreements are a result of the understanding reached with the Competent Authority of United Kingdom some time ago. The Competent Authorities of India and UK had earlier exchanged mutual agreements amongst them under the Mutual Agreement Procedure (MAP) Article of the India-UK Double Taxation Avoidance Convention (DTAC).
These 3 agreements cover international transactions in the nature of payment of intra-group service charges and pertain to the telecom industry. They also have a roll-back provision. With this, India and UK have concluded 5 bilateral APAs and some more would be concluded in the near future. The total number of bilateral APAs concluded so far by the CBDT is 7.
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.