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ARTICLE · 30 OCTOBER 2012

India Introduces Guidelines For Advance Pricing Arrangement Program

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On August 30, 2012, the Central Board of Direct Taxes ("CBDT") issued guidance on its advance pricing arrangement ("APA") program.

IndiaTax
Dale Hill
Dale Hill
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INTRODUCTION

On August 30, 2012, the Central Board of Direct Taxes ("CBDT") issued guidance on its advance pricing arrangement ("APA") program. This release provides critical guidance to taxpayers and brings in much needed rules to introduce the APA program in India. The introduction of the APA program is designed to give taxpayers greater certainty on international transactions between related parties operating in two or more tax jurisdictions. Much of the guidance discusses provisions that, in name, are similar to those implemented in countries where transfer pricing legislation is more developed, such as Canada. The release of this guidance is welcomed. The news signals that India is serious about providing taxpayers with a clear framework for gaining tax certainty.

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