India debates changing course on APAs

June 28 2011

The Indian government is rumoured to have changed tack on its structuring of the upcoming advance pricing arrangement (APA) programme. Taxpayers expected a unilateral APA to be incorporated into the Direct Taxes Code in 2012 but officials could be bending to arguments from lobbyists that this way of establishing certainty about transfer pricing would be arbitrary. Sophie Ashley takes a fresh look at the APA process and considers the pros and cons to unilateral and bilateral APAs.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

Feature India Quarterly August-October 2011 (May 2011)

more across site & shared bottom lb ros

More from across our site

Direct Tax

UK pound,money of United kingdom close up on white, Pound UK not

US pillar two side-by-side deal will cost UK £700m per year

The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser

Tom Baker, March 03 2026

Direct Tax

Creative destruction and digital tax: reflecting on the 2025 Nobel Prize

Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance

Nitin Agarwal, March 03 2026

Podcasts

Editable TT 640x360 article-thumbnail (2).png

Taxing Times: introducing ITR’s new monthly podcast

Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution

Tom Baker, March 02 2026

Direct Tax

‘Potential to raise standards’: mixed adviser reaction to HMRC registration system

While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors

Sam Sholli, March 02 2026

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Pillar two will prosper despite US side-by-side arrangement

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos

Paul Monaghan, February 27 2026

Direct Tax

This week in tax: PwC commences legal battle with boutique consultancy founded by ex-COO

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week

Sam Sholli, February 27 2026

Direct Tax

Washington DC Capitol view on cloudy sky background

Ex-US Supreme Court advocate convicted on 12 counts in tax trial

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff

Sam Sholli, February 26 2026

Transfer Pricing

Suited figure pointing to audit among various hexagonal icons

TP documentation in a fragmented world: how to limit audit triggers

Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions

Daniel Moalusi, February 26 2026

Direct Tax

‘Tax at breaking point’: Thomson Reuters’ AI tech hits one million users

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR

Sam Sholli, February 24 2026

Direct Tax

Deloitte unveils €20bn EMEA combination

The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth

Tom Baker, February 24 2026