CBDT signed BAPA with Indian subsidiary of Japanese trading company

The Central Board of Direct Taxes (CBDT) on 13 January 2017 entered into a Bilateral Advance Pricing Agreement (BAPA) with an Indian subsidiary of a Japanese trading company.
●    With the signing of this agreement, the total number of bilateral APAs entered into by the CBDT has reached eight.
●    Recently, the CBDT modified an existing Bilateral APA with another Indian subsidiary of a Japanese company.
●    All these bilateral APAs were signed as part of the Advance Pricing Agreement Scheme of the Union Ministry of Finance.
●    The Union Government has introduced the Advance Pricing Agreement (APA) Scheme as part of the Finance Act, 2012 and Income Tax (Tenth Amendment) Rules, 2012. The scheme came into force on 30 August, 2012.
●    The APA Scheme endeavours to provide certainty to taxpayers in the field of transfer pricing through an agreement in advance. 
●    Such an agreement is entered into by the CBDT with the tax payers on the transfer price of international transactions between associated entities.