India Scores the Highest Figure of Bilateral Agreements (APAs) Since its Release   

September 1, 2023

The Indian Revenue Authority has reached the figure of 95 Advance Pricing Agreements (APAs) during the fiscal year 2022-2023, which is a record number of bilateral agreements according to the recent APA report since the release of the program in 2012. 

1. APAs Program 

The Tax Directorate started with the APA Program, one of the most important initiatives for promoting investment, avoiding conflicts between the taxpayer and tax administrations, reducing compliance control costs, and increasing legal certainty for taxpayers.  

 The APA program was released in 2012 under the Finance Act 2012. 

2. Period 2022-2023 

During that period, a total of 193 APA applications were filed, of which 77 were bilateral APA applications. In addition to the aforementioned, more than half of the bilateral APA applications were made jointly with the United States. The other partner countries that have filed a large number of applications this fiscal year include Japan, Finland, South Korea, and the United Kingdom.  

Of the 449 APA applications filed through March 31, 2023, 140 disposed of, and 309 in process. On the other hand, 47 are under “reversion.” 

3. Projected Time 

The average time to conclude bilateral APAs has been reduced to 62 months in FY 2022-23, approximately. 

Source: Transferpricingnews