The progress of the Advanced Price Agreement scheme strengthens the Government’s resolve of fostering a non-adversarial tax regime. Comment (200 Words)
Refer - Business Standard
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IAS Parliament 5 years
KEY POINTS
An APA is an agreement between a taxpayer and the tax authority determining the Transfer Pricing methodology for pricing the tax payer’s international transactions for future years. An APA provides certainty with respect to the tax outcome of the tax payer’s international transactions.
An APA can be one of the three types – unilateral, bilateral and multilateral.
· A Unilateral APA is an APA that involves only the taxpayer and the tax authority of the country where the taxpayer is located.
· Bilateral APA (BAPA) is an APA that involves the tax payer, associated enterprise (AE) of the taxpayer in the foreign country, tax authority of the country where the taxpayer is located and the foreign tax authority.
· Multilateral APA (MAPA) is an APA that involves the taxpayer, two or more AEs of the tax payer in different foreign countries, tax authority of the country where the taxpayer is located and the tax authorities of AEs.
Significance:
· The Indian APA programme has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner.
· APAs met an overwhelming response with an increase in the number of applications filed, from 146 in FY13 to a cumulative 1,145 applications as of March 2019, with the CBDT concluding 271 APAs (including 31 bilateral APAs) and the remaining awaiting resolution.
· APAs concluded by the CBDT encompass a range of issues, such as royalties, intra-group services, guarantee fees, economic adjustments and so on. The US, the UK, Singapore, Australia and Germany are prominent counterparty jurisdictions wherein majority of APAs have been concluded.
The DOLs 5 years
Plz evaluate
IAS Parliament 5 years
Good answer. Try to underline key points. Keep Writing.
DIPANJAN HAZRA 5 years
please check
IAS Parliament 5 years
Good answer. Keep Writing.
Krish 5 years
Kindly evaluate sir,Thank u
IAS Parliament 5 years
Good answer. Keep Writing.
