The Central Board of Direct Taxes (CBDT) achieved a historic milestone in the financial year 2023-24 by sealing a record-breaking 125 Advance Pricing Agreements (APAs) with taxpayers. This significant achievement underscores the government's commitment to fostering an environment conducive to business, particularly for large multinational corporations engaged in extensive cross-border transactions among their subsidiaries.

The CBDT highlighted that this feat marks the highest number of APA signings in any fiscal year since the inception of the APA program. Compared to the preceding financial year, the number of APAs signed surged by an impressive 31%, reaching a total of 641 agreements since the program's initiation.

A key driver behind this surge in agreements was the collaborative efforts with India's treaty partners, including Australia, Canada, Denmark, Japan, Singapore, the UK, and the US. By entering into mutual agreements with these nations, India has further strengthened its commitment to providing certainty to taxpayers in the realm of transfer pricing.

Under the APA Scheme, taxpayers benefit from predetermined pricing methods, ensuring clarity on the arm's length price of international transactions for up to five years into the future. Moreover, taxpayers have the option to roll back the APA for the preceding four years, extending tax certainty to a total of nine years.

Notably, bilateral APAs offer an added advantage by shielding taxpayers from the risk of double taxation, whether anticipated or actual.

This milestone underscores India's proactive approach in facilitating a conducive business environment while upholding tax compliance and fairness in cross-border transactions, ultimately fostering economic growth and investor confidence.