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Financials
In a significant boost to its efforts to streamline cross-border business operations and enhance tax efficiency, India has achieved a historic milestone by signing a record number of Advance Pricing Agreements (APAs) during the 2024-25 financial year. This development marks a crucial step forward in the country's push towards ease of doing business, particularly for multinational corporations involved in extensive international transactions.
APAs are critical instruments used by tax authorities and taxpayers to mutually agree on how to price transactions between related companies in different countries. These agreements are designed to provide certainty in transfer pricing, a key area where disputes often arise. By specifying the pricing methods in advance, APAs can prevent potential tax disputes and reduce the risk of double taxation, thereby offering stability and predictability for businesses operating across borders.
The APA program was introduced in India through the Finance Act of 2012, which took effect on July 1, 2012. Since its inception, the program has grown significantly, reflecting the government's commitment to fostering a business-friendly environment. Over the years, India has signed a substantial number of APAs, but the latest record surpasses all previous achievements.
In the 2024-25 fiscal year, the Central Board of Direct Taxes (CBDT) signed a staggering 174 APAs, marking the highest number since the program's launch. This milestone not only highlights the efficiency of the current regime but also underscores the collaborative efforts between the government and taxpayers.
The APA program has contributed substantially to India's mission to enhance ease of doing business. By providing clarity and certainty in transfer pricing, APAs help multinational enterprises involved in cross-border transactions navigate the complex landscape of international tax laws more effectively.
The latest APAs are a result of collaborative efforts with several treaty partners, including Australia, Japan, South Korea, The Netherlands, New Zealand, Singapore, the UK, and the US. This cooperation underscores the global outlook of India's tax policies and its commitment to maintaining harmonious international relationships.
The record-breaking number of APAs signed during the 2024-25 fiscal year is a testament to India's evolving tax landscape. As the country continues to strengthen its position as a major player in global trade, the APA program will likely play an increasingly important role in fostering a stable and transparent business environment. With its innovative approach to tax certainty and collaborative spirit, India is well-positioned to attract more foreign investment and reinforce its status as a vital hub for international business operations.
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