APA Conclusions – CBDT Update – FY 2024-25
As the financial year came to a close yesterday, the Central Board of Direct Taxes (CBDT) has issued a press release with the statistics of APA conclusions during the FY 24-25. It has been a record year for the APA and some of the key highlights are as below.
- Highest number of APAs signed in a single year since the scheme’s inception (174 APAs signed during FY 24-25), which is a 39% increase from FY 23-24
- Highest number of BAPAs finalised in any year (Out of 174 APAs, 65 were BAPAs i.e. almost 40% of the APAs signed during FY 24-25), which is a 67% increase from FY 23-24
- Highest number of APAs signed on a single day (34 APAs on 27 March 2025)
- India’s first MAPA (Multilateral APA i.e. with more than two countries involved) signed
The BAPAs were majorly signed with India’s treaty partners Australia, Japan, South Korea, Netherlands, New Zealand, Singapore, UK and US. This has brought the total number of APAs signed since inception to 815 (615 UAPAs, 199 BAPAs and 1 MAPA). A copy of the press release is appended here.
The consistent increase in conclusion of APAs in India (From 95 in FY 22-23, 125 in FY 23-24 to 174 in FY 24-25) is encouraging for taxpayers and demonstrates the CBDT’s commitment in reducing the inventory of pending APA applications and providing tax certainty. Further the signing of the first MAPA is significant and should hopefully open doors for filing of many more MAPA applications.
While the threshold for Safe Harbour has been increased recently to INR 300 crores, there has been no significant inclusion/change in transactions covered, and hence APA would continue to be a viable option for taxpayers for dispute prevention and resolution, for varied complex nature of transactions.
The US IRS has also recently issued its annual APMA report which specified that the highest number of BAPAs executed during 2024 was with India (29%), which shows that India was a significant party in the US APA programme with successful interactions between the Competent Authorities.