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.


Related content

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.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal



KPMG's new digital platform

KPMG International has created a state of the art digital platform that enhances your experience, optimized to discover new and related content.