First Bilateral APA with Japanese company with Rollback provision making it fourth bilateral Advance Pricing Agreement signed by CBDT
Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes
New Delhi, 4th August, 2016.
PRESS RELEASE
Sub: Signing of Bilateral Advance Pricing Agreement by CBDT
The Central Board of Direct Taxes (CBDT) entered into a Bilateral Advance Pricing Agreement (APA) on 2nd August, 2016 with the Indian subsidiary of a Japanese trading company. This is the first Bilateral Advance Pricing agreement with a Japanese company having a “Rollback” provision in it. Overall, it is fourth bilateral APA signed by CBDT. Signing of this bilateral APA is an important step towards ascertaining certainty in transfer pricing matters of multinational company cases and dispute resolution.
The APA Scheme was introduced in the Income-tax Act in 2012 and the “Rollback” provisions were introduced in 2014. The scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and setting the prices of international transactions in advance.
The progress of the APA Scheme strengthens the Government’s mission of fostering a non-adversarial tax regime. The CBDT expects more APAs to be concluded and signed in the near future.
(Meenakshi J. Goswami)
Commissioner of Income Tax
(Media and Technical Policy)
Official Spokesperson, CBDT.
- If assessee fails to explain source of purchases, estimating profit rate contrary to Section 69C
- Income Tax Department not trusted even upon its lawyers – SC slams ITD for delay
- Goods loaded in two trucks with one e-way bill stating both truck numbers – No evasion
- GOI makes four new Labour Codes effective from 21st November 2025
- Provident fund dues have first charge over claim of bank under SARFAESI Act – SC
