The Central Board of Direct Taxes (‘CBDT’), vide press release dated March 31, 2025, has announced its achievement of signing a record Advance Pricing Agreements (‘APAs’) during the Financial Year (‘FY’) 2024-25.

As per the press release, 174 APAs have been signed during FY 2024-25. The statistics of APAs signed (Unilateral, Bilateral and Multilateral) during FY 2024-25 vis-à-vis APAs signed during the previous FY i.e., FY 2023-24 are provided in the tabular format as below:

As per the press release, the Bilateral APAs signed this year have also marked a record, showcasing India’s strengthening cooperation with global tax treaty partners, particularly Australia, Japan, South Korea, Netherlands, New Zealand, Singapore, UK, and US.

KNAV Comments:

The APA programme is the finest offering of the CBDT in terms of providing tax certainty and resolving disputes proactively. The CBDT’s continued and incremental commitment to this program highlights its role in fostering a conducive business environment, promoting transparency, and enhancing taxpayer confidence through collaborative approaches. This approach has been pivotal in making the APA scheme a cornerstone of India’s tax / transfer pricing framework for multinational corporations, emphasizing its role in aligning with global best practices in tax administration.

Further, the accomplishments of FY 2024-25 extend the positive impact of the APA program on India’s ease of doing business landscape, particularly benefiting entities involved in intricate international transactions. The initiative will not only help to prevent disputes over transfer pricing but also ensure consistency and reliability in tax obligations across borders. Through APA, the taxpayer will achieve certainty over a period of 9 years (including rollback period).

The increasing trend of bilateral APAs shows taxpayers’ perception of security and safeguarding themselves against potential or actual instances of double taxation in different jurisdictions.