CBDT Releases The Fifth Annual APA Report

Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes
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New Delhi, 1st September, 2023
Press Release
CBDT Releases The Fifth Annual APA Report
The Advance Pricing Agreement (APA) programme of CBDT is one of its
foremost initiatives for promoting an investor-friendly and non-adversarial tax regime
in India. Since its commencement in July, 2012, the Indian APA programme has
contributed significantly to the Government of India’s mission of promoting ease of
doing business.
The Central Board of Direct Taxes (CBDT) has recently released the fourth
and fifth annual APA reports. The reports present key data and statistics pertaining
to the APA programme. These include sectoral distribution of applicants, nature of
transactions covered, transfer pricing methodologies applied etc.
The fifth report includes status of applications filed till 31st March, 2023. The
statistics are updated till Financial Year (FY) 2022-23, for the present. The report
highlights various achievements of the APA programme 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 programme, signing a total of 95 APAs.
CBDT also signed 32 Bilateral Advance Pricing Agreements (BAPAs) in FY
2022-23 being the maximum number of BAPAs in any financial year till 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 record of the largest number of single day signings in the history of the
programme was also created with a total of 21 APAs signed on 24th March, 2023.
Additionally, signing of the 400th Unilateral Advance Pricing Agreement (UAPA) and
the 500th APA were also milestones achieved in this year. The report is available at :
https://incometaxindia.gov.in/Lists/Latest%20News/Attachments/601/APA-Report-Final-2023.pdf.
CBDT stands committed to strengthen the APA programme further.
(Surabhi Ahluwalia)
Pr. Commissioner of Income Tax
(Media and Technical Policy) &
Official Spokesperson, CBDT