On 14 March 2015, the Indian Central Board for Direct Taxes published a notice for the implementation of APA roll-back provisions. The plan to introduce rollback provisions was initially announced in the 2014-2015 budget.
With the implementation, taxpayers that enter into APAs with India will be allowed to apply the terms of the APA for the covered related party transactions for a rollback period of up to 4 years. The standard maximum term of an APA is 5 years.
Taxpayers who hav…