Indian Tax Administration Relaxes Norms for MAP and Bilateral APAs
The Indian government had taken the position previously that the mutual agreement procedure (MAP) for transfer pricing disputes and bilateral advance pricing agreements (APA) could not be permitted when Article 9(2) or an equivalent Article was not present in the double tax avoidance agreement (DTAA...
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Published in | Journal of International Taxation Vol. 29; no. 3; p. 7 |
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Main Authors | , , , |
Format | Trade Publication Article |
Language | English |
Published |
Boston
Thomson Reuters (Tax & Accounting) Inc
01.03.2018
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Subjects | |
Online Access | Get full text |
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Summary: | The Indian government had taken the position previously that the mutual agreement procedure (MAP) for transfer pricing disputes and bilateral advance pricing agreements (APA) could not be permitted when Article 9(2) or an equivalent Article was not present in the double tax avoidance agreement (DTAA) with the other country (the jurisdiction of the group entity having transactions with India). Now, through a press release issued on Nov 27, 2017, the government has said that the MAP for TP disputes and the bilateral APA process would be available to taxpayers even when Article 9(2) or the equivalent is not present in the DTAA with the taxpayer's jurisdiction. The following summarizes the key considerations and implications of this revised approach. |
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ISSN: | 1049-6378 |