Question: What is the total number of Advance Pricing Agreements entered into by the Central Board of Direct Taxes so far?
(a) 145
(b) 140
(c) 142
(d) 141
Ans: (d)
- On 6th March, 2017, the Central Board of Direct Taxes (CBDT) entered into a bilateral Advance Pricing Agreement (APA) with rollback provision with a Japanese subsidiary.
- The total number of APAs entered into by the CBDT has reached 141 with this signing. The CBDT expects more APAs to be concluded and signed before the end of the current fiscal.
- With this signing, the total number of bilateral APAs with Japanese subsidiaries has reached five, all with rollback provisions.
- Four APAs out of these five have been signed in the current financial year. 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.