Global Partner. Integrated Solutions.
1 April 2026
CBDT surpasses its previous record by signing 219 APAs including 84 BAPAs in FY 25-26
 
  • The Central Board of Direct Taxes (CBDT) has yet again recorded the highest ever number of Advance Pricing Agreements (APAs) signed with 135 Unilateral APAs (UAPAs) and 84 Bilateral APAs (BAPAs) for the relevant financial year. With this, the CBDT has crossed 1000 mark with a total of 1034 APAs, including 750 UAPAs and 284 BAPAs.

  • The rise in the BAPAs signings was driven by the conclusion of Mutual Agreements with 13 of India's treaty partners, namely the US, Finland, the UK, Singapore, Japan, South Korea, Australia, Denmark, Sweden, France, Indonesia, Ireland and New Zealand. FY 25-26 also marks the first year for signing India's first ever bilateral APAs with France, Ireland, Indonesia, and Sweden.

      Number of APAs Signed year-wise till 31 March 2026


  • India's efforts to enhance tax certainty are evident in The Finance Act, 2026 which introduced significant amendments to the Safe Harbor Rules (SHR). It is also recommended to conclude the UAPA involving transactions relating to provision of information technology services within 2 years. If required, a 6-month extension may be granted at the taxpayer discretion.
Our Comments

While the contribution of the Central Board of Direct Taxes has been instrumental in the successful implementation of the APA program, the collaborative approach and active participation of taxpayers as key stakeholders have also been crucial. The Government's sustained efforts in this regard have furthered its objective of enhancing the ease of doing business for multinational enterprises (MNEs) in India and strengthening investor confidence.
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