The APA is an attempt of the department to provide tax certainty to the tax payer as it reduces risk of double taxation and provides added clarity to the taxpayer.
We deal in the following 3 types of APA:
- Unilateral APA: Between the tax payer and the tax authority.
- Bilateral APA: Between the tax payer, its overseas group entity, the Competent authority of taxpayer and component authority of taxpayer’s overseas group entity.
- Multilateral APA: Between the tax payers, its overseas group entities, the competent authority of taxpayer and respective component authority of taxpayer’s overseas group entities.