Advance Pricing Agreement (APA) Scheme
The Government has introduced the Advance Pricing Agreement (APA) Scheme through Finance Act, 2012 and Income Tax (Tenth Amendment) Rules, 2012 notified vide S.O. 2005(E) with effect from 30th August, 2012.
The APA Scheme endeavours to provide certainty to taxpayers in the field of transfer pricing through an agreement in advance. Such agreement is entered into by the CBDT with the approval of the Central Government, with the tax payers on the transfer price of international transactions between associated entities. Relevant provisions are contained in Sections 92CC and 92CD of the Income Tax Act, 1961 and Rules 10F to 10T and Rule 44GA of the Income Tax Rules, 1962.
Six agreements have been executed till date.
The US Governments has agreed to open the process for admitting applications requesting bilateral APA between US and India.
This was stated by Shri Jayant Sinha, Minister of State in Ministry of Finance in written reply to a question in the Lok Sabha today.
