Synopsis
The Central Board of Direct Taxes (CBDT) achieved a milestone by signing 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25, the highest in a single financial year since the program's inception. This trend reflects strengthened collaborations with treaty partners and the commitment to enhance the ease of doing business.Key Takeaways
- CBDT signed a record 174 APAs in FY 2024-25.
- 65 were Bilateral APAs, a record for any year.
- Overall, 815 APAs have been signed since the program began.
- The APA Scheme provides certainty in transfer pricing.
- 34 APAs were signed in one day on March 27, 2025.
New Delhi, March 31 (NationPress) The Central Board of Direct Taxes (CBDT), the leading authority of the Income Tax Department, has achieved a milestone by signing a remarkable 174 Advance Pricing Agreements (APAs) with Indian taxpayers for the financial year 2024-25, as stated in an official announcement released on Monday.
This achievement represents the highest count of APAs finalized in a single financial year since the program's inception. Out of the 174 APAs signed, 65 were Bilateral APAs (BAPAs), marking the largest number concluded in this category within any year to date. These agreements resulted from collaborative negotiations with India’s treaty partners, including Australia, Japan, South Korea, the Netherlands, New Zealand, Singapore, the UK, and the US, as per the CBDT statement.
Since the program started, the overall count of APAs has now reached 815, which includes 615 Unilateral APAs, 199 Bilateral APAs (BAPAs), and one Multilateral APA.
The CBDT has consistently maintained a strong momentum in finalizing APAs, having signed 125 in FY 2023-24 and 95 in FY 2022-23. This year also witnessed the signing of India’s inaugural MAPA. Notably, on March 27, 2025, a historic 34 APAs were finalized in a single day, the statement highlighted.
The APA Scheme is designed to offer certainty to taxpayers in transfer pricing by defining pricing methods and establishing the arm’s length price of international transactions in advance for a period of up to five years. BAPAs provide the additional advantage of protection against potential or actual double taxation.
The APA program has made a significant impact on the Indian government's initiative to improve the ease of doing business, particularly for multinational companies involved in substantial cross-border transactions. The CBDT appreciates the collaborative efforts of taxpayers and acknowledges their vital role as key stakeholders in the successful execution of the APA program, the statement further noted.
Each executed APA delivers tax certainty for a taxpayer over multiple years. In addition to effectively managing the unilateral aspect of the APA program, the CBDT has actively collaborated with various tax treaty partners to negotiate and establish Bilateral APAs, which afford taxpayers the additional benefit of alleviating double taxation. The record number of bilateral agreements finalized this year also signifies the strengthening of relationships with taxpayers and treaty partners, a senior official commented.
