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Transfer Pricing: Relaxation for MAP and bilateral APA

One of the condition for acceptance of applications for Transfer Pricing Mutual Agreement Procedure (MAP) cases and bilateral Advance Pricing Agreements (APAs) was compulsory presence of Article 9(2) relating to ‘Corresponding Adjustment’ in the DTAA applicable to Associated Enterprise (AE) of the Indian entity.

 

CBDT has received a number of references from time to time regarding the acceptance of applications pertaining to Transfer Pricing Mutual Agreement Procedure (MAP) cases and bilateral Advance Pricing Agreements (APAs) where the DTAA applicable to AE of the Indian entity does not contain Paragraph 2 of Article 9 (or its relevant equivalent Article) relating to ‘Corresponding Adjustment’.

 

CBDT has now issued press release dated 27th November, 2017 and has given relaxation to accept MAP and bilateral APA applications regardless of the presence or otherwise of Article 9(2) or its relevant equivalent article in DTAAs