Bilateral APA provides the added benefit of preventing potential or actual double taxation.
The Central Taxation Commission (CBDT), the administrative and decision-making body of the income tax department, said in a statement that it had entered into 174 APAs with Indian taxpayers during the fiscal year 2024-25.
It added that these include unilateral APA (UAPA), bilateral APA (BAPA) and multilateral APA (MAPAS).
The board said it was the “highest number” of APAs signed in a single fiscal year since the program was launched.
It signed 125 APAs during the 2023-24 fiscal year and 95 APAs in 2022-23. According to official data, major economies such as France, Japan and Germany did not sign any APAs during the current fiscal period, while the United States signed 142 such agreements. Of the 174 APAs, 65 are Bapas, which is again the “highest” number finalized in any year according to the statement.
CBDT said the fiscal year also saw the first ever MAPA signing contract in India.
CBDT said the APAs are the result of consensus with Indian treaty partners, including Australia, Japan, South Korea, the Netherlands, New Zealand, Singapore, the United Kingdom and the United States.
It said that over the years, the total number of APAs is now 815, including 615 UAPAs, 199 Bapas and 1 MAPA.
“The APA program has made a significant contribution to the Indian government’s mission to improve its business, especially for multinational companies engaged in extensive cross-border transactions.
According to CBDT, “CBDT recognizes the collaborative spirit of taxpayers and values the role of key stakeholders in the successful implementation of the APA program”.
