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New Delhi, November 18, 2016: India and Britain on Friday signed three more bilateral Advance Pricing Agreements (APAs) taking the total number of these pacts to a total of 111 so far, an official statement said.

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“The Central Board of Direct Taxes (CBDT) signed three three bilateral APAs here today taking the total number of APAs signed (both-bilateral and unilateral) so far to 111,” the Finance Ministry said in a statement.

“These three agreements cover international transactions in the nature of payment of intra-group service charges and pertain to the telecom industry. They also have a roll-back provision,” the statement said.

With this, India and Britain have concluded five bilateral APAs and some more would be concluded in the near future, it added.

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Authorities from both countries had earlier exchanged mutual agreements amongst them under the Mutual Agreement Procedure (MAP) Article of the India-UK Double Taxation Avoidance Convention (DTAC).

The Advance Pricing Agreement programme was introduced by the Finance Act, 2012 with a view to provide a predictable and non-adversarial tax regime and to reduce the litigation in the Indian transfer pricing arena.

An APA can be entered into for a maximum of five years at a time. Since the notification of the APA scheme on August 30, 2012, a total of about 700 APA applications have been received during the first four years of the programme, which indicates the wide acceptance by the taxpayers, it said.

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“The Indian APA programme has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner,” it added. (IANS)


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