India has released its APA annual report, providing valuable insight into recently filed APAs and the process.
- Intragroup services by the Indian applicants have been the most covered international transactions in the bilateral APAs.
- The transaction net margin method has been used in 70% of the unilateral cases and 90% of the bilateral cases.
- India has concluded unilateral APAs in 29 months and bilateral APAs in 39 months.
As India is recognized as very creative and aggressive in its transfer pricing practices, this report should be reviewed to test whether an APA should be filed, as well as in other countries for additional certainty.
EY’s Global Tax Alert provides additional details, included for reference.