India signs highest-ever international transaction APAs in 2024-25

New Delhi: A record 174 Advance Pricing Agreements (APAs) were signed with Indian taxpayers in the 2024-25 financial year ending on Monday, the CBDT said.

The APA scheme aims to provide tax "certainty" to entities 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.

Bilateral APAs offer the added benefit of protection against potential or actual double taxation.

The Central Board of Direct Taxes (CBDT), the administrative and policy-making body for the Income-Tax Department, said in a statement that it has entered into a record 174 APAs with Indian taxpayers during the 2024-25 fiscal.

These include Unilateral APAs (UAPAs), Bilateral APAs (BAPAs) and Multilateral APAs (MAPAs), it added.

The Board said this was the "highest number" of APAs signed in a single financial year since the programme's launch.

It had signed 125 APAs during the 2023-24 fiscal and 95 in 2022-23.

Major economies like France, Japan and Germany did not sign any APA during the current fiscal, while the US entered into 142 such agreements, as per official data.

Of the 174 APAs, 65 were BAPAs, which is again the "highest" number of such agreements finalised in any year so far, as per the statement.

The current financial year also saw the signing of India's first-ever MAPA, the CBDT said.

These APAs are 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, the CBDT said.

The total number of APAs, across all the years, now stands at 815, comprising 615 UAPAs, 199 BAPAs and 1 MAPA, it said.

"The APA programme has significantly contributed to the government of India's mission to enhance ease of doing business, particularly for multi-national 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 programme," as per the CBDT.