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India, Japan Sign Fifth Bilateral Advance Pricing Agreement

by Mary Swire, Tax-News.com, Hong Kong

08 March 2017


India has signed a bilateral advance pricing agreement with the Indian subsidiary of a Japanese company, India's Central Board of Direct Taxes (CBDT) has announced.

The APA was signed on March 6. With this, India and Japan have concluded five bilateral APAs, all of which include roll-back provisions. Overall, the CBDT has signed ten bilateral APAs and expects more APAs to be concluded and signed in the near future.

The CBDT said: "All these five bilateral APAs are with Japanese trading companies (Sogo Soshas). Certainty in tax treatment for Sogo Soshas has been a long-standing demand of the Japanese industry. The bilateral signing of APAs in this sector provides tax certainty up to nine years in each of these cases."

The APA scheme was introduced in the Income Tax Act in 2012 and rollback provisions were newly permitted from 2014.

TAGS: tax | business | India | law | ministry of finance | tax authority | agreements | transfer pricing | advance pricing agreement (APA) | tax reform | trade | Japan | Tax

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