Recommendations for a modelAdvance Pricing Agreement scheme in India |
Deloitte is pleased to announce the release of its latest transfer pricing white paper – RECOMMENDATIONS FOR A MODEL ADVANCE PRICING AGREEMENT (APA) SCHEME in INDIA”. In particular, this white paper is in support of the introduction by the Government of India of The Direct Taxes Code, 2010 (Bill No.110 of 2010) and the provisions in that Bill (proposed new s.118) for the use of APAs to address compliance with India’s transfer pricing rules.
At the outset, Deloitte welcomes the introduction of APA measures. Similar measures are already in operation in many of the tax systems of India’s trading partners, investors, and it is Deloitte’s experience that such measures successfully deliver benefits such as reduced cost of compliance, reduced risk of audit and penalty, reduced tax litigation, tax certainty, fairness, simplicity and efficiency to the taxpayers that conclude APAs. It is understood that tax authorities involved in APAs consider similar benefits are derived by them.
This white paper draws on Deloitte’s extensive international knowledge and experience of APAs, and best practice in the operation of such arrangements, with a view to making recommendations for the scheme of agreements to be employed in India. Accordingly, while we recommend this white paper to you and trust that it provides useful and practical insights for your business, we also trust that the recommendations will be useful for tax authorities when framing an APA scheme for India.
Deloitte remains committed to being a knowledge driven organization. We aim to develop cogent thought papers which look at issues and deliver useful insights to those issues. If you want deeper insights on any or all of the topics we have presented, please do not hesitate to contact us with any questions or comments.
Advance Pricing Agreement
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