New Delhi, March 31 The Income Tax Department has signed a record 219 Advance Pricing Agreements (APAs) with Indian taxpayers in the current fiscal year to enhance ease of doing business by providing tax certainty.
This includes Unilateral APAs (UAPAs) and Bilateral APAs (BAPAs), the Central Board of Direct Taxes (CBDT) said in a statement on Tuesday.
With this, the total number of APAs since the inception of the APA programme has crossed the 1,000th mark, aggregating to 1,034 APAs, comprising 750 UAPAs and 284 BAPAs, it said.
"This year, the CBDT again recorded the highest ever APA signings in any financial year since the launch of the APA programme, signing a total of 219 APAs. This year, the CBDT also signed 84 BAPAs, exceeding the record of 65 BAPAs signed last year in FY 2024-25," it said.
BAPAs were signed pursuant to entering into 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, it said.
Notably, this year also marks the achievement of signing India’s first-ever bilateral APAs with France, Ireland, Indonesia and Sweden, it said, adding that the CBDT has consistently been signing a high number of APAs, having concluded 174 APAs in the previous financial year and 125 APAs in the year before that.
Safe Harbour Rules complement the Advance Pricing Agreement (APA) framework by offering a faster, lower-cost alternative for achieving transfer pricing certainty, it said.
Introduced in 2013, it said, the Safe Harbour framework prescribes fixed margins for specified categories of international transactions.
The regime currently spans twelve transaction categories, including IT and software services, IT-enabled services, KPO, contract R&D, intra-group financing, guarantees, auto components, low value-adding services, and certain transactions in the diamond industry, it said.
The Finance Act 2026 has introduced significant enhancements to the Safe Harbour Rules.
"Multiple technology service segments have been consolidated into a single 'Information Technology Services' category with a uniform 15.5 per cent margin. The eligibility threshold has been increased from Rs 300 crore to Rs 2,000 crore. The amendments also introduce a more system-driven and automated framework, reducing the need for detailed scrutiny and administrative interface," it said.
The APA Scheme, together with Safe Harbour Rules, aims to provide certainty to taxpayers in the area of transfer pricing by specifying pricing methods and determining the arm's length price of international transactions in advance for up to five years, it said.
BAPAs offer the added benefit of protection against potential or actual double taxation. The CBDT recognises the collaborative spirit of taxpayers and values their role as key stakeholders in the successful implementation of the APA programme, it added.