CBDT Sets Record With 219 Advance Pricing Agreements in FY26

Overview

• India’s tax authority said it signed 219 APAs in FY 2025–26, the most in a single year, taking the cumulative APA count to 1,034.
• The department also closed 84 bilateral APAs with 13 treaty partners, including first-ever deals with France, Indonesia, Ireland and Sweden.
• APAs are advance deals that lock in how related-party cross-border prices will be set, while bilateral APAs coordinate with a partner country to prevent the same income being taxed twice.
• Officials said the expanded APA pipeline reduces transfer-pricing disputes and gives companies clearer rules so they can plan investments with more confidence.
• Alongside the APA push, new Safe Harbour updates set a single 15.5% margin for information technology services, raise the eligibility cap to Rs 2,000 crore, and move filings to a more automated process to lower scrutiny and cost.