To provide certainty to foreign investors in transfer pricing, the Central Board of Direct Taxes (CBDT) has entered into 11 more unilateral Advance Pricing Agreements (APAs), according to Shefali Shah, Principal Commissioner of Income Tax (OSD) and official spokesperson of CBDT.
In a communique, she said these APAs were signed with Indian subsidiaries of foreign companies operating in various segments of the economy like investment advisory services, engineering design services, marine products, contract R&D, software development services, IT enabled services, cargo handling support services, etc.
While seven of these APAs have rollback provisions contained in them, the other four are agreements for future five years. APAs with rollback provisions can cover a maximum period of nine years in total. With this round of signing, CBDT has so far entered into 31 APAs (30 unilateral and one bilateral).
The APA programme was introduced in 2012. Five APAs were concluded in the first year and four more were signed in the second year.
The pace of negotiations has picked up in the current year which has already witnessed the conclusion of 22 APAs. She said the department aimed at finalizing another 30 to 40 APAs before the end of this fiscal to provide stability and confidence to foreign enterprises operating in India.