The Central Board of Direct Taxes (CBDT) on 22 May 2017 signed two Unilateral Advance Pricing Agreements (APA) with Indian taxpayers.
Among these two agreements, one also has a Rollback Provision.
The two APAs signed pertain to chip design and development of embedded software and Information technology sectors of the economy.
With the signing of these two APAs, the number of APAs signed in Financial Year 2017-18 is now four.
The progress of the APA Scheme is directly proportional to the Union Government’s commitment to foster a non-adversarial tax regime.
The APA Scheme was introduced in the Income-tax Act, 1961 in 2012 and the Rollback Provisions were introduced in 2014.
The scheme aims to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and setting the prices of international transactions in advance for the maximum of five future years.
Further, the taxpayer has the option to roll-back the APA for four preceding years, as a result of which, total nine years of tax certainty is provided.
Since its inception, the APA scheme has showcased a lot of interest from taxpayers that has resulted in filing of over 700 applications in about five years.
