India's transfer pricing rules were introduced in 2001, and the government introduced an advance pricing agreement (APA) mechanism in July 2012. Since then nearly 150 applications have been received and the first five agreements were signed March 31st 2014.
The Indian tax authorities are quite aggressive in terms of transfer pricing, and the conclusion of the first APAs is a positive development for both tax payers and the tax authorities.
The APA rules allow for unilateral, bilateral, and mu…