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The Government of India has resolved over 100 transfer pricing disputes with the US under a Framework Agreement signed back in January 2015, India's Central Board of Direct Taxes (CBDT) announced on January 28.
The Agreement was signed under the mutual agreement procedure (MAP) provision of the India-US tax treaty to resolve transfer pricing disputes. The Agreement is expected to resolve about 200 existing transfer pricing disputes involving US companies with operations in India.
Earlier, on August 6, 2015, the CBDT said that, while 35 disputes stood resolved as at that date, another 100 were likely to be resolved over the next months.
The CBDT noted that the success of the Agreement in just one year has led US tax authorities to open up their bilateral advance pricing agreement (APA) program to India. "The US is expected to begin accepting bilateral APA applications shortly. Prior to resolution of disputes under the Framework Agreement, the US bilateral APA program was closed to India," it said.
The CBDT added that the MAP programs with countries such as Japan and the UK are also progressing very well, with regular meetings being held to resolve past disputes.
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