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INTERNATIONAL AFFAIRS
U.S. TAX AUTHORITIES APPROVE SIGNING OF BILATERAL APAS WITH INDIA
February 6, 2016
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1.The U.S. Internal Revenue Service on Tuesday announced that, starting February 16, its Advance Pricing and Mutual Agreement office will begin accepting requests for bilateral advance pricing agreements between the U.S. and India. This marks a big step forward to ensure tax certainty between the two countries, according to experts.

2.This hesitation to enter into bilateral APAs might have been due to the large number of pending transfer pricing cases between the US and India, according to some experts. The two countries had around 200 cases pending for the last 4-5 years, 100 of which were resolved recently, according to the Indian government. Real progress in resolving these cases was made following the signing of the framework agreement between the Indian and the U.S. tax authorities in January 2015 as part of the Mutual Agreement Procedure (MAP) provision contained in the India-U.S. Double Taxation Avoidance Convention (DTAC).