India resolves over 100 transfer pricing disputes with US

Tribune News Service

New Delhi, January 28

The government today said more than 100 cases of transfer pricing disputes with the US have been resolved which would boost investments by MNCs. The Finance Ministry said the Central Board of Direct Taxes (CBDT) has signed an agreement with the revenue authorities of the US in January 2015.

This agreement was finalised under the Mutual Agreement Procedure (MAP) provision contained in the India-USA Double Taxation Avoidance Convention (DTAC). The agreement seeks to resolve about 200 past transfer pricing disputes between the two countries in the Information Technology (Software Development) Services (ITS) and Information Technology enabled Services (ITeS) segments.

The statement said more than 100 cases have already been resolved and some more are expected to be resolved before the end of this fiscal.

Prior to resolution of disputes under the framework agreement, the US bilateral APA programme was closed to India. The success of the framework Agreement in short period of one year has led to the US revenue authorities opening up their bilateral APA programme to India. The US is expected to begin accepting bilateral APA applications shortly.