India: Report of APA statistics

Author: KPMG

The first annual report of the advance pricing agreement (APA) programme in India has been released by the Central Board of Direct Taxes, Ministry of Finance. The APA report provides insights into the progress of APA programme in India, as introduced in 2012.


The APA programme in India was launched in July 2012 with the objective of providing certainty to taxpayers in respect of the transfer prices of cross-border transactions undertaken by taxpayers with their group entities. This programme, now almost five years old, has offered an alternate dispute resolution mechanism to taxpayers in respect of transfer pricing issues.

The APA report reveals the following statistics:


  • 815 APA applications were filed as of 31 March 2017 (688 applications for unilateral APAs and 127 bilateral APA applications).
  • 152 APAs have been signed (141 unilateral APAs and 11 bilateral APAs).
  • 78 APAs of the 152 approved APAs have "rollback provisions."
  • Of the 11 bilateral APAs, six are with the UK and five are with Japan.


The United States opened its bilateral APA programme with India in February 2016, and since then, there has an increase in the number of bilateral APA applications and in the number of conversions from unilateral APAs applications to bilateral APA applications.


Read a May 2017 report [PDF 287 KB] prepared by the KPMG member firm in India.


Related Resources