06 December 2017 Indian Tax Administration relaxes norms for MAP and bilateral APAs The Indian Government previously had taken the position that the Mutual Agreement Procedure (MAP) for transfer pricing (TP) disputes and bilateral Advance Pricing Agreements (APAs) could not be permitted where 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 November 27, the Indian Government has stated that the MAP for TP disputes and the bilateral APA process would be available to taxpayers even where Article 9(2) or the equivalent is not present in the DTAA with the taxpayer's jurisdiction. Document ID: 2017-2060 |
