An APA is an agreement between a taxpayer and the tax authority that establishes the transfer pricing method for setting the prices of the taxpayer`s international transactions for years to come. An APA provides certainty about the tax results of the taxpayer`s international transactions. The Central Board of Direct Taxes (CBDT) signed the 300th Pre-Price Contract (APA) in September. This is an important step in the Indian APP program, now in its seventh year. The APAs were set up in India in 2012 at the network level: the problem with multilateral agreements and what India must do to win most of them The Central Council of Direct Taxes (CBDT) concluded 2 bilateral pre-price agreements (APAs) in November 2017. These two agreements are for the first time bilateral APA with the Netherlands. These two APAs cover the electronics and technology economics. It also includes international transactions, distribution, provision of business assistance services, provision of .. The progress of the APA program reinforces the government`s commitment to promoting a non-contradictory tax system. The Indian APA program has been valued nationally and internationally for its ability to deal with complex transfer pricing issues in a fair and transparent manner. APA is a mechanism for resolving transfer pricing disputes in advance.

Transactions between related parties (z.B. an Indian subsidiary that makes software development available to its U.S. parent company) must be arm-length, which means that there is no need to grant an unfair pricing advantage. The Central Board of Direct Taxes (CBDT), the political decision-making body of the Department of Income Tax, signed seven unilateral pre-price agreements (APAs) in October 2017. Thus, the total number of APAs received by CBDT is now 184. These include 171 unilateral APAs and 12 bilateral APAPs. In the current fiscal year, a total of 32 APAs (2. A pre-price agreement (APA) is a prior agreement between a tax payer and a tax authority on an appropriate transfer pricing method (TPM) for a number of transactions involved during a specified period[1] (“covered transactions”). However, it is possible that a subject may be able to negotiate a unilateral APA involving only the taxpayer and the IRS. In this case, both parties negotiate an appropriate TPM only for U.S. tax purposes. If the taxpayer is involved in a dispute with a foreign tax authority over the registered transactions, he can apply for a discharge by asking the competent US authority to initiate a procedure of mutual agreement.

This, of course, implies the entry into force of an applicable foreign income tax agreement. Bilateral and multilateral APAs are generally bilateral or multilateral, i.e. they also enter into agreements between the subject and one or more foreign tax administrations under the control of the Mutual Agreement Procedure (POP) under the tax treaties. [3] The subject benefits from such agreements, since he is assured that income from covered transactions is not subject to double taxation on the part of the IRS and the relevant foreign tax authorities.