CBDT releases the fifth annual APA report

01 Sep 2023: The Advance Pricing Agreement (APA) program of CBDT is one of its foremost initiatives for promoting an investor-friendly and non-adversarial tax regime in India. Since its inception, the Indian APA program has contributed significantly to the Government of India’s mission of promoting ease of doing business.

CBDT releases the fifth annual APA report

The Central Board of Direct Taxes (CBDT) has recently released the fourth and fifth annual APA reports. The reports present key data and statistics about the APA program. These include sectoral distribution of applicants, nature of transactions covered, transfer pricing methodologies applied, etc.

The status of applications filed till 31st March 2023

The fifth report includes the status of applications filed till 31st March 2023. The statistics are updated till the Financial Year (FY) 2022-23, for the present. The report highlights various achievements of the APA program in FY 2022-23. In FY 2022-23, CBDT recorded the highest-ever APA signings in any financial year since the launch of the APA program, signing a total of 95 APAs.

CBDT also signed 32 Bilateral Advance Pricing Agreements (BAPAs) in FY 2022-23 which is the maximum number of BAPAs in any financial year to date. This figure is more than double the previous signing record of 13 BAPAs in any financial year. 

The report also details the country-wise distribution of these applications. The BAPAs were signed as a consequence of entering into Mutual Agreements with India’s treaty partners namely Finland, the UK, the US, Denmark, Singapore, and Japan, showcasing the maturity of India’s relationship with various treaty partners.

A total of 21 APAs signed on 24th March 2023

A record of the largest number of single-day signings in the history of the program was also created with a total of 21 APAs signed on 24th March 2023. Additionally, the signing of the 400th Unilateral Advance Pricing Agreement (UAPA) and the 500th APA were also milestones achieved this year. The report is available at:

CBDT stands committed to strengthening the APA program further. 

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