Date: 2026-03-31Category: Press ReleaseState: Union GovernmentCountry: India
CBDT signs record 219 Advance Pricing Agreements (APAs) in FY 2025–26, taking total number of APAs beyond milestone of 1000 (i.e. 1034) since inception
**Executive Summary**
In FY 2025-26, the Central Board of Direct Taxes (CBDT) signed a record 219 Advance Pricing Agreements (APAs), surpassing a total of 1,000 agreements since the program's inception. These achievements, reported on March 31, 2026, aim to enhance tax certainty and ease of doing business through high-volume Bilateral APAs and significant reforms to Safe Harbour Rules. The Finance Act 2026 further streamlines compliance by increasing eligibility thresholds and automating administrative frameworks.
**Key Points / Main Content**
**APA Program Performance**
* **Record Signings:** A total of 219 APAs were signed in FY 2025-26, the highest in any single financial year.
* **Cumulative Milestone:** Total APAs reached 1,034 (750 Unilateral and 284 Bilateral) since the program began.
* **Bilateral Advancements:** 84 Bilateral APAs (BAPAs) were concluded this year, including India’s first-ever BAPAs with France, Ireland, Indonesia, and Sweden.
* **International Cooperation:** BAPAs were finalized following mutual agreements with 13 treaty partners, including the US, UK, Japan, and Singapore.
**Safe Harbour Rules (SHR) Reforms**
* **Threshold Increase:** The eligibility threshold for the Safe Harbour regime has been raised from Rs. 300 crore to Rs. 2,000 crore.
* **Category Consolidation:** Multiple technology service segments are now merged into a single "Information Technology Services" category.
* **Uniform Margins:** A standardized 15.5% margin has been established for the consolidated IT services category.
* **Automation:** The framework is transitioning to a system-driven and automated process to reduce manual scrutiny and administrative interface.
**Operational Objectives**
* **Tax Certainty:** The APA scheme specifies pricing methods and arm's length prices for international transactions for up to five years.
* **Cost Efficiency:** Safe Harbour Rules provide a faster, lower-cost alternative to the standard APA process for achieving transfer pricing certainty.
* **Mitigation of Double Taxation:** BAPAs specifically offer protection against potential or actual double taxation.
**Impact Analysis**
**Indian Taxpayers and MNEs**
**Impact**
Taxpayers benefit from increased certainty in transfer pricing for up to five years and reduced risks of double taxation. A larger number of entities now qualify for the simplified Safe Harbour regime due to the expanded Rs. 2,000 crore threshold.
**Action Required**
Eligible taxpayers should assess their international transactions against the new 15.5% margin for IT services and utilize the automated framework for future compliance filings.
**Central Board of Direct Taxes (CBDT)**
**Impact**
The department experiences a more efficient administrative process due to the reduction in detailed scrutiny requirements and the implementation of a system-driven framework.
**Action Required**
Maintain the collaborative approach with international treaty partners and continue implementing the automated reforms introduced by the Finance Act 2026.
Key Entities Referenced
Central Board of Direct Taxes (CBDT): The primary regulatory body responsible for administering direct tax laws in India and entering into record-breaking Advance Pricing Agreements with taxpayers.
Advance Pricing Agreement (APA) Scheme: A tax certainty programme that determines the arm's length price of international transactions in advance for up to five years.
Safe Harbour Rules: A regulatory framework providing fixed margins for international transactions as a faster, lower-cost alternative to the APA process.
Finance Act 2026: The legislative act that introduced significant enhancements to the Safe Harbour Rules, including category consolidation and increased eligibility thresholds.
Ministry of Finance
CBDT signs record 219 Advance Pricing
Agreements (APAs) in FY 2025–26, taking total
number of APAs beyond milestone of 1000 (i.e.
1034) since inception
With 84 Bilateral APAs (BAPAs), highest ever in a single year
and new milestones achieved with key treaty partners, APA
programme continues to strengthen tax certainty and
improve ease of doing business
This framework is further reinforced by recent reforms in Safe
Harbour Rules, enhancing efficiency, transparency, and
compliance
Posted On: 31 MAR 2026 8:25PM by PIB Delhi
The Central Board of Direct Taxes (CBDT) has entered into a record 219 Advance Pricing Agreements
(APAs) in FY 2025-26 with Indian taxpayers. This includes Unilateral APAs (UAPAs) and Bilateral APAs
(BAPAs). With this, the total number of APAs since the inception of the APA programme has crossed the
1000th mark, aggregating to 1034 APAs, comprising 750 UAPAs and 284 BAPAs.
This year, CBDT again recorded the highest ever APA signings in any financial year since the launch of
the APA programme, signing a total of 219 APAs. This year, CBDT also signed 84 BAPAs, crossing the
record of 65 BAPAs signed last year in FY 2024-25. The BAPAs were signed pursuant to entering into
Mutual Agreements with 13 of India’s treaty partners namely the US, Finland, the UK, Singapore, Japan,
South Korea, Australia, Denmark, Sweden, France, Indonesia, Ireland and New Zealand. Notably, this
year also marks the achievement of signing India’s first-ever bilateral APAs with France, Ireland,
Indonesia and Sweden. CBDT has consistently been signing a high number of APAs, having concluded
174 APAs in the previous financial year, and in the year before that, 125 APAs were concluded.
Safe Harbour Rules complement the Advance Pricing Agreement (APA) framework by offering a faster,
lower-cost alternative for achieving transfer pricing certainty. Introduced in 2013, the Safe Harbour
framework prescribes fixed margins for specified categories of international transactions. The regime
currently spans twelve transaction categories, including IT and software services, IT-enabled services,
KPO, contract R&D, intra-group financing, guarantees, auto components, low value-adding services, and
certain transactions in the diamond industry.
The Finance Act 2026 has introduced significant enhancements to the Safe Harbour Rules. Multiple
technology service segments have been consolidated into a single “Information Technology Services”
category with a uniform 15.5% margin. The eligibility threshold has been increased from Rs. 300 crore toRs. 2,000 crore. The amendments also introduce a more system-driven and automated framework,
reducing the need for detailed scrutiny and administrative interface.
The APA Scheme, together with Safe Harbour Rules, aims to provide certainty to taxpayers in the area of
transfer pricing by specifying pricing methods and determining the arm's length price of international
transactions in advance for up to five years. BAPAs offer the added benefit of protection against potential
or actual double taxation. CBDT recognises the collaborative spirit of taxpayers and values their role as
key stakeholders in the successful implementation of the APA programme.
✅CBDT has signed a record 219 Advance Pricing Agreements (APAs) in FY
2025–26, taking the total number of APAs beyond the milestone of 1000 (i.e.
1034) since inception.
✅With 84 Bilateral APAs (BAPAs), the highest ever in a single year and new
milestones achieved with key… pic.twitter.com/amG4xnxnq0
— Income Tax India (@IncomeTaxIndia) March 31, 2026
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NB/KMN
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