New Delhi, March 31 The Central Board of Direct Taxes (CBDT), the apex body of the Income Tax Department, entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25, according to an official statement released on Monday.
This marks the highest number of APAs signed in a single financial year since the programme was launched. Of the 174 APAs that were signed, 65 were Bilateral APAs (BAPAs), which is the highest number finalised in this category in any year so far. These were a result of mutual agreements with India’s treaty partners, including Australia, Japan, South Korea, the Netherlands, New Zealand, Singapore, the UK, and the US, the CBDT statement said.
The total number of APAs since the inception of the programme has now reached 815, comprising 615 Unilateral APAs, 199 Bilateral APAs (BAPAs), and one Multilateral APA.
The CBDT has maintained a consistent pace in concluding APAs, having signed 125 in FY 2023-24 and 95 in FY 2022-23. Notably, this year also saw the signing of India’s first-ever MAPA. Additionally, on March 27, 2025, a record 34 APAs were signed on a single day, the statement pointed out.
The APA Scheme aims to provide certainty to taxpayers in the area of transfer pricing by specifying pricing methods and determining the arm’s length price of international transactions in advance for up to five years. BAPAs offer the added benefit of protection against potential or actual double taxation.
The APA programme has significantly contributed to the Indian government’s mission to enhance ease of doing business, particularly for multinational enterprises engaged in extensive cross-border transactions. The CBDT recognises the collaborative spirit of taxpayers and values their role as key stakeholders in the successful implementation of the APA programme, the statement added.
Each signed APA brings tax certainty for a taxpayer that spans multiple years. Apart from running the unilateral leg of the APA programme successfully, the CBDT has also actively engaged with its various tax treaty partners to negotiate and enter into Bilateral APAs, which provide taxpayers an added benefit of relieving double taxation. The record numberrecord number of bilateral agreements signed this year also reflects the strengthening of our relationship with taxpayers and treaty partners, a senior official said.
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