India - Reports APA Programme Statistics and Developments for FY 2025-26

Summary

The Central Board of Direct Taxes (CBDT) published the Advance Pricing Agreement Annual Report for Financial Year 2025-26, providing information on the operation of India’s Advance Pricing Agreement (APA) programme, including APA agreements concluded during the reporting period, the status of unilateral and bilateral APAs, and the administration of the APA framework under the Indian transfer pricing regulations.

Key points

APA Programme Overview

The CBDT Annual Report provides information on the operation of the Advance Pricing Agreement programme administered by the Indian tax authorities.

The APA programme enables taxpayers and tax authorities to agree in advance on the determination of the arm’s length price or the manner of determining the arm’s length price for covered international transactions and specified domestic transactions.

The report describes the development and administration of the APA programme during Financial Year 2025-26.

APA Agreement Statistics

The Annual Report provides statistics regarding APA agreements concluded during Financial Year 2025-26.

The statistics include information relating to:

• Total APA agreements concluded during the reporting period;

• Unilateral APA agreements;

• Bilateral APA agreements; and

• Cumulative progress of the APA programme since its introduction.

Bilateral APA Developments

The report provides information regarding bilateral APA agreements concluded through discussions between the Indian competent authority and competent authorities of treaty partner jurisdictions.

Bilateral APA procedures are conducted under the mutual agreement procedure provisions contained in applicable tax treaties.

The report includes information regarding bilateral APA activities undertaken during the reporting period.

Unilateral APA Developments

The report provides information regarding unilateral APA agreements concluded between taxpayers and Indian tax authorities.

Unilateral APAs establish agreed transfer pricing approaches between taxpayers and the Indian tax administration for covered transactions.

APA Application Processing

The Annual Report provides information regarding the processing of APA applications during Financial Year 2025-26.

The report includes information regarding:

• APA applications received;

• APA applications processed;

• APA agreements concluded; and

• Applications pending before the tax authorities.

Covered Transactions under the APA Programme

The APA programme applies to international transactions and specified domestic transactions subject to the Indian transfer pricing provisions.

The Annual Report provides information regarding transactions covered under APA agreements concluded under the programme.

APA Framework under Indian Transfer Pricing Regulations

The report describes the APA framework established under the Indian Income-tax Act, 1961 and related transfer pricing provisions.

The framework provides procedures for taxpayers to submit APA applications and for tax authorities to evaluate and conclude APA agreements.

Source:

Central Board of Direct Taxes (CBDT), Advance Pricing Agreement Annual Report 2025-26

https://www.incometaxindia.gov.in/

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Disclaimer:

This content is for general informational purposes only and does not constitute professional advice.

Information provided herein is based on publicly available sources as of the publication date and may be subject to change.

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