CASC Article on “Strategic Deliberation of APA Feasibility: Specific Business Scenarios”
VSTN has recently published an article “Strategic Deliberation of APA Feasibility: Specific Business Scenarios” co authored by Nithya Srinivasan and E Rajesh in the CASC Monthly Bulletin of January 2025.
The article mainly dwells on key considerations that taxpayers and businesses will have to bear in mind before filing APA application with respect certain transaction groups and business scenarios. The article also covers key costs heads w.r.t. Advance Pricing Agreement, from the filing of APA application and on post APA compliances.
This article aims to provide inputs that would facilitate taxpayers and businesses to make a more informed decision before filing of APA or during feasibility analysis before deciding APA as the most appropriate Dispute resolution mechanism.
Considering that in the recent APA report issued by CBDT for FY 2023-24 there has been a record number of APAs concluded- total of 125 (86 UAPA, 39 BAPA) and BAPAs filed – 78 and the pending inventory as % of the total applications dipped to 46% as at FY 23-24 from 50% as at FY 22-23 signalling a good momentum.
VSTN Article’s also emphasises that it is best taxpayers approach the APA program for the appropriate cases, to ensure that APA forum is not clogged with cases which would have obtained dispute resolution through another forum, efficiently.