CBDT signs record 219 APAs in FY26; total crosses 1,000-mark
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The Central Board of Direct Taxes (CBDT) has signed a record 219 Advance Pricing Agreements (APAs) with Indian taxpayers in FY25–26, marking the highest number of such agreements concluded in a single financial year.
The total includes both Unilateral APAs (UAPAs) and Bilateral APAs (BAPAs). With this, the cumulative number of APAs since the programme’s inception has crossed the 1,000-mark, reaching 1,034 agreements, comprising 750 UAPAs and 284 BAPAs.
During the year, CBDT also signed 84 BAPAs, surpassing the previous record of 65 in FY24–25. These agreements were concluded following mutual agreements with 13 treaty partners, including the United States, United Kingdom, Japan, Singapore, Australia, France, Ireland, Indonesia, and Sweden, among others. Notably, FY26 marked the first-ever bilateral APAs signed with France, Ireland, Indonesia, and Sweden.
The APA programme has seen consistent growth in recent years, with 174 agreements signed in FY24–25 and 125 in FY23–24.
CBDT said the APA framework, complemented by Safe Harbour Rules, aims to provide certainty to taxpayers on transfer pricing by determining the arm’s length price of international transactions in advance for up to five years. BAPAs further help mitigate the risk of double taxation.
Introduced in 2013, the Safe Harbour regime offers a simplified, lower-cost alternative for transfer pricing compliance by prescribing fixed margins for specified international transactions. It currently covers 12 categories, including IT and software services, IT-enabled services, contract R&D, intra-group financing, guarantees, auto components, and low value-adding services.
The Finance Act 2026 has introduced key changes to the Safe Harbour Rules. These include consolidating multiple technology service segments into a single “Information Technology Services” category with a uniform margin of 15.5%, raising the eligibility threshold from ₹300 crore to ₹2,000 crore, and introducing a more automated, system-driven framework to reduce compliance burden, and administrative intervention.
CBDT said the continued expansion of the APA programme reflects strong taxpayer participation and its role in enhancing tax certainty and ease of doing business in India.