India: First APA rollback signed | KPMG | BE
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India: First APA rollback signed; concerns U.S. company

India: First APA rollback signed; concerns U.S. company

India signed its first advance pricing agreement (APA) rollback—a unilateral APA rollback with a U.S. multinational company—since the rollback rules were notified by the Central Board of Direct Taxes (CBDT) in March 2015.


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The APA rollback rules in India provide for an extension of the terms of an APA concerning the pricing of international transactions for the prior four years preceding the first year from which the APA is to apply.


The APA signed with the U.S. company covers a period of nine years, thereby providing certainty and litigation protection for the past four years and for the future five years.


It has been reported that eight more APA rollback agreements are expected to be signed in the coming month.


Read an August 2015 report [PDF 387 KB] prepared by the KPMG member firm in India: Advance Pricing Agreement rollback – India signs its first rollback agreement 

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