India APA – FY 23-24

India’s record tally of APA concluded – FY 2023-24

The Ministry of Finance issued a press release yesterday, 16 April 2024, on the total number of AdvancePricingAgreement concluded in FY 2023-24 between CBDT and taxpayers.

FY 2023-24 marked a milestone of highest number of total APAs concluded as well highest unilateral APA (UAPA) and bilateral APA (BAPA), individually. Total number of APAs concluded were 125, first year the 100-mark was crossed, around 32% increase from the FY 22-23. UAPA also witnessed a significant increase of about 37% from FY 22-23 viz., 86 in FY 23-24 from 63 in FY 22-23. BAPA witnessed a margin increase to 39 in FY 23-24 from 32 in FY 22-23. Treaty partners with whom BAPA was concluded include Australia, Canada, Denmark, Japan, Singapore, UK and US.

The increase in conclusion of UAPA is a result of commitment by the CBDT to improve the efficacy of APA programme, resulting in reduction in inventory of pending APA applications. Sustained increase in BAPA concluded also points that APA programme is maturing towards complete dispute resolution.

Dispute prevention programmes such APA provide significant relief to taxpayers, thereby reducing costs and efforts of taxpayers in transferpricing litigation and the Indian APA programme has displayed continued commitment in wholistic dispute resolution.