Advance Pricing Agreements (APA)
Long-term pricing certainty through India's APA programme — one of the most active and successful in the world. We manage strategy, filing and negotiation end-to-end.
Fix your methodology for up to nine years
An APA locks in a transfer pricing methodology with the CBDT — and, for bilateral/multilateral cases, a treaty partner — for five prospective years, with rollback available for up to four preceding years. That's up to nine years of TP certainty from a single, well-run process.
Who this applies to
Companies with recurring, material related-party transactions seeking multi-year certainty rather than annual audit-defence.
Every type of APA
Unilateral APA
Agreement with the Indian tax authority alone — the fastest route to certainty.
Bilateral APA
Joint negotiation with a treaty partner's competent authority, eliminating double taxation risk.
Multilateral APA
Coordinated agreement covering transactions across multiple jurisdictions.
Rollback
Extending the agreed methodology to up to four preceding years.
From feasibility to signed agreement
Feasibility & Pre-Filing
Informal consultation with the APA authority to gauge viability.
Application
Prepare and file Form 3CED with functional and economic analysis.
Negotiation
Represent you through fact-finding and methodology negotiation.
Signing & Compliance
Finalise the agreement and manage ongoing annual compliance reporting.
Real APA negotiation experience, not just paperwork
Cross-Border Coordination
Direct liaison with overseas advisors for bilateral cases.
Feasibility-First Approach
We assess viability honestly before recommending an APA.
Multi-Industry Track Record
APAs supported across IT/ITES, manufacturing, pharma and more.
Common questions
Considering an APA for long-term certainty?
Get a free feasibility assessment.
Related: Mutual Agreement Procedure · Safe Harbour Rules · APA Guide (Blog)