Advance Pricing Agreement Annual Report

The chart below and the graph below show the number of unilateral APAs received over the past 5 years. The number of agreements signed in 2018-19 has decreased by 30% compared to 2017-18. In 2017-18, a similar decrease was also recorded compared to 2016-17. The reasons for this slowdown have already been mentioned in this report. The China Advance Pricing Arrangement (APA) Annual Report for 2019 summarizes information on the APA programme in China and highlights the tax administration`s determination to regularly promote the APA program and improve the quality of services provided by tax authorities to taxpayers. – Reducing or eliminating the risk of transfer pricing adjustments, penalties and interest, as well as the risk of double taxation The Indian APP program has matured since its launch in July 2012. This is evidenced by the number of notifications filed and agreements signed. The complex problems of transfer pricing, which were subject to lengthy litigation, are increasingly resolved by asAS. The resolutions were to the satisfaction of both taxpayers and the government. While over the past five or nine years, taxpayers have been able to obtain certainty on transfer pricing issues (depending on whether the return rules apply to an agreement), the government has been successful in redirecting resources from audit and process procedures to more productive work. In addition, the APA also ensures that the government, on the basis of the terms of the agreements, receives revenue from large taxpayers. While revenue mobilization has never been the priority objective of India`s APP program, it is a positive external impact of the program, which provides the Indian government with additional revenue and guarantees.

It is estimated that the 271 signed APAs generated additional revenues of approximately Rs. 10,000. Crore. The result is a payment of taxes and interest of approximately 3600 crore without going into litigation or litigation. From the inception of the APA program in 1991 until December 31, 2019, the IRS received a total of 2,670 APP applications and executed 1,940 APAs. In the table below, you will find summary statistics on APP applications for 2019, exported APAs and pending AAPs. Data are reported separately for unilateral and bilateral APAs and completion times for 2019, 2018 and 2017 are compared.