
doi: 10.2139/ssrn.2338920
To avoid the double taxation and to preserve time from frenzy litigation procedures, countries enters into a Mutual agreement procedure (MAP), which is one of the provisions under the Double taxation avoidance agreements, through which competent authorities of the countries signing the agreement decides the destination and division of the taxes to be charged by each country so as to avoid the payment double taxation on the same product. MAP takes time as it is post assessment process. To reduce this time some countries have Advanced pricing agreement schemes(APA), to determine in advance the Arms length pricing (ALP) of the future international transactions. In India this was introduced for the first time through Finance act 2012, to bring certainty to the International Transactions. The introduction of Indian APA rules brings silver lining to violent transfer pricing regime and may emerge as a game changer in Indian transfer pricing landscape. This paper will provide a useful and practical insight and prove helpful to understand the new APA regime and to see if it is pertinent to consider it for International transfer pricing agreements.
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