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Industry & Economy - Taxation


`Time not ripe for advance pricing arrangement'

Our Bureau

New Delhi , Jan. 25

MULTINATIONAL corporations and international companies with business interests in India may have to wait longer before they could avail themselves of an advance pricing arrangement (APA) for their transfer pricing issues.

An APA is an arrangement between a taxpayer and the tax authority wherein the method of determining the transfer pricing for inter-company transactions are set out in advance. Such programmes are designed to resolve actual or potential transfer pricing disputes in a cooperative manner, say tax experts. APA programmes are also an alternative to the traditional dispute resolution process such as transfer pricing audit.

The Finance Ministry has now made it clear that time is not ripe for any immediate introduction of an APA programme in the country.

"The roadmap to an APA is slightly long. I don't see (the possibility of having) a APA programme immediately in place. APA programme requires lot of technically competent people and we are trying to build it," a senior Finance Ministry official said at an international tax conference organised by the India branch of International Fiscal Association. Finance Ministry officials also have mixed views about the benefits of APA.

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