Advance
Pricing Agreements (UAPAs) with Indian taxpayers. . .
The Central Board of Direct Taxes (CBDT) has entered into 9 Unilateral
Advance Pricing Agreements (UAPAs) with Indian taxpayers in July, 2017. With
this, total number of APAs signed till date stands at 171 (Bilateral-12 and
Unilateral-159). The nine APAs signed pertain to diverse sectors of the economy
including Oil & Gas exploration, education, banking, pharmaceutical,
manufacturing and IT. They also cover international transactions and provision
of software development services, ITES , engineering design services,
distribution, contract manufacturing, etc.
APAs provide for signing an agreement between a taxpayer and the income
tax department on an appropriate transfer pricing methodology for determining the
value of assets and taxes on intra-group overseas transactions.
The scheme attempts 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.
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