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What is an Advance Pricing Agreement (APA)?

CBDT Signs 95 Advance Pricing Agreements

  1. What is an Advance Pricing Agreement (APA)? Answer: An Advance Pricing Agreement (APA) is an agreement between a taxpayer and tax authority determining the transfer pricing methodology for pricing the taxpayer's international transactions for future years.

  2. How many Advance Pricing Agreements (APAs) did CBDT sign in FY 2022-23? Answer: CBDT signed a record 95 Advance Pricing Agreements (APAs) in FY 2022-23.

  3. What is the difference between a Unilateral APA (UAPA) and a Bilateral APA (BAPA)? Answer: A Unilateral APA (UAPA) involves only the taxpayer and the tax authority of the country where the taxpayer is located, while a Bilateral APA (BAPA) involves the taxpayer, associated enterprise (AE) of the taxpayer in the foreign country, tax authority of the country where the taxpayer is located, and the foreign tax authority.

  4. What is the purpose of an APA? Answer: The purpose of an APA is to determine the transfer pricing methodology for pricing the taxpayer's international transactions for future years.

  5. How has the APA programme contributed to the Government of India's mission of promoting ease of doing business? Answer: The APA programme has contributed significantly to the Government of India's mission of promoting ease of doing business, especially for MNEs which have a large number of cross-border transactions within their group entities.

  6. What is the composition of CBDT? Answer: CBDT consists of a Chairman and six Members, including Member (Income Tax & Revenue), Member (Legislation), Member (Administration), Member (investigation), Member (TPS & system), and Member (Audit & Judicial).

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