THE Central Board
of Direct Taxes (CBDT) yesterday entered into a bilateral Advance Pricing
Agreement (APA) with rollback provision with a Japanese subsidiary. The
total number of bilateral APAs signed with Japanese subsidiaries has thus
reached five, all with rollback provisions. Four APAs out of these five have
been signed in the current financial year.
All these five bilateral APAs are with Japanese trading companies (Sogo Soshas). Certainty in tax treatment for Sogo Soshas has been a long standing demand of the Japanese industry. The bilateral signing of APAs in this sector provides tax certainty up to nine years in each of these cases.
|
No. of Advance Pricing Agreements signed
|
|
S.No
|
Financial Year
|
Unilateral APAs
|
Bilateral APAs
|
Total
|
|
1
|
2013-14
|
5
|
0
|
5
|
|
2
|
2014-15
|
3
|
1
|
4
|
|
3
|
2015-16
|
53
|
2
|
55
|
|
4
|
2016-17 (up to 6-03-2017)
|
69
|
8
|
77
|
|
Total
|
130
|
11
|
141
|
The total number of APAs entered into by the CBDT has reached 141 with this signing. The CBDT expects more APAs to be concluded and signed before the end of the current fiscal.
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