The Central Board of Direct Taxes (CBDT) entered into nine Unilateral Advance Pricing Agreements (UAPAs) with Indian taxpayers in the month of July 2017. The APA Scheme endeavors to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the Arm’s Length Price of international transactions in advance for a maximum period of five future years. CBDT has signed its first APA with a taxpayer engaged in supplying rigs used in Oil & Gas exploration. The international transactions covered in these nine APAs include provision of software development services, engineering design services, distribution, contract manufacturing, etc.

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