CBDT signs 174 advance pricing agreements in FY 2024-25

ANI March 31, 2025 216 views

The CBDT has set a new record by signing 174 Advance Pricing Agreements in FY 2024-25, including India's first multilateral APA. A significant 65 of these were bilateral agreements with key treaty partners like the US and UK. The APA program provides tax certainty for multinationals by pre-setting transfer pricing methods. This initiative supports India's goal of improving ease of doing business for global enterprises.

"This marks the highest number of APAs signed in a single financial year since the program's launch." – CBDT Official
New Delhi, March 31: The Central Board of Direct Taxes (CBDT) entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25. These includes Unilateral APAs (UAPAs), Bilateral APAs (BAPAs) and Multilateral APAs (MAPAs). With this, the total number of APAs since the inception of the programme has reached 815, comprising 615 UAPAs, 199 BAPAs and 1 MAPA, said an official

Key Points

1

CBDT signed 174 APAs in FY 2024-25

2

Includes 65 BAPAs with treaty partners like US and UK

3

First-ever MAPA finalized this year

4

APA scheme ensures tax certainty for multinationals

This marks the highest number of APAs signed in a single financial year since the program's launch. Of the 174 APAs signed, 65 were BAPAs, the highest number of BAPAs finalised in any year so far. These were a result of Mutual Agreements with India's treaty partners, including Australia, Japan, South Korea, The Netherlands, New Zealand, Singapore, the UK, and the US.

CBDT has maintained a consistent pace in concluding APAs, having signed 125 in FY 2023-24 and 95 in FY 2022-23. Notably, this year also saw the signing of India's first-ever MAPA. Additionally, on 27th March 2025, a record 34 APAs were signed on a single day.

The APA Scheme aims to provide certainty to taxpayers in the area of transfer pricing by specifying pricing methods and determining the arm's length price of international transactions in advance for up to five years. BAPAs offer the added benefit of protection against potential or actual double taxation.

The APA programme has significantly contributed to the Government of India's mission to enhance ease of doing business, particularly for multinational enterprises engaged in extensive cross-border transactions. CBDT recognises the collaborative spirit of taxpayers and values their role as key stakeholders in the successful implementation of the APA program.

Tags:
CBDT Advance Pricing Agreements APA Tax certainty Multinational companies Transfer pricing BAPAs
You May Like!