CBDT signs 174 Advance Pricing Agreements in Financial Year 2024-25

The Central Board of Direct Taxes (CBDT) entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25.

These include unilateral APAs (UAPAs), bilateral APAs (BAPAs), and multilateral APAs (MAPAS). With this, the total number of APAs since the program’s launch has reached 815, including 615 UAPAs, 199 BAPAs, and one MAPA.

This is the highest number of APAs signed in a single financial year since the program’s inception. Of the 174 APAs signed, 65 were BAPAs, the most in any year to date. These were the outcome of mutual agreements with India’s treaty partners, which included Australia, Japan, South Korea, the Netherlands, New Zealand, Singapore, the United Kingdom, and the United States.

CBDT has kept a regular pace of signing APAs, having signed 125 in FY 2023-24 and 95 in FY 2022-23. Notably, this year marked the signing of India’s first MAPA. Additionally, on March 27, 2025, a record 34 APAs were signed in a single day.

The APA Scheme aims to give taxpayers with transfer pricing certainty by outlining pricing procedures and calculating the arm’s length price of foreign transactions up to five years in advance. BAPAs offer the extra benefit of protection against prospective or real double taxation.

The APA programme has made a substantial contribution to the Government of India’s objective to improve ease of doing business, particularly for multinational corporations involved in extensive cross-border transactions. CBDT recognises taxpayers’ collaborative spirit and values their role as vital partners in the effective implementation of the APA program.