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

1. At a Glance

Advance Pricing Agreement (APA) is a contract between the Central Board of Direct Taxes (CBDT) and a taxpayer that pre-determines the Arm's Length Price (ALP) or methodology for international transactions between Associated Enterprises (AEs), reducing transfer-pricing disputes [S1][S2].
CBDT signed a record 219 APAs in FY 2025–26, taking the cumulative tally past the 1,000 mark to 1,034 (750 Unilateral + 284 Bilateral) since inception in 2012 [S1].
Relevant for UPSC GS-III (Indian Economy — taxation, ease of doing business) and Prelims (statutory provisions, ministries, recent indices).

On 31 March 2026, PIB released that CBDT entered into 219 APAs in FY 2025–26, the highest ever in a single year [S1].
Includes 84 Bilateral APAs (BAPAs) — also the highest-ever annual BAPA count, breaking last year's record of 65 BAPAs in FY 2024–25 [S1].
Coincides with recent reforms in Safe Harbour Rules to bolster tax certainty and ease of doing business [S1].

APA programme launched 1 July 2012 via insertion of Sections 92CC and 92CD in the Income-tax Act, 1961 by the Finance Act, 2012 [S2].
APA Scheme (Rules 10F–10T) notified in the Income-tax Rules, 1962 vide Notification No. 36/2012 dated 30 August 2012 — programme became fully operational [S2].
Rollback provision introduced by Finance (No. 2) Act, 2014 — allows APA to apply to 4 preceding years in addition to the 5 future years [S2].
Annual sign-ups have risen: 62 (FY 2021-22) → 95 (FY 2022-23) → 125 (FY 2023-24) → record 219 (FY 2025-26) [S1].

Implementing body: Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance [S1].
Statutory base: Sections 92CC & 92CD, Income-tax Act, 1961; Rules 10F–10T, Income-tax Rules, 1962 [S2].
Maximum tenure: 5 future years + 4 rollback years = 9 years of price certainty [S2].
Types: Unilateral APA (UAPA) — only with CBDT; Bilateral APA (BAPA) — with CBDT + foreign tax authority via DTAA Mutual Agreement Procedure (MAP); Multilateral APA (MAPA) [S1][S2].
Cumulative tally (as of FY 2025-26): 1,034 APAs = 750 UAPAs + 284 BAPAs [S1].
BAPA treaty partners in FY 2025-26 (13): USA, UK, Japan, Singapore, South Korea, Australia, Finland, Denmark, Sweden, France, Indonesia, Ireland, New Zealand [S1].

Economic: Reduces transfer-pricing litigation, providing certainty on tax outcomes for MNEs operating in India; strengthens ease of doing business metrics [S1].
Legal/Constitutional: Operates under statutory provisions (Sec 92CC/CD); BAPAs invoke India's DTAA network through the Mutual Agreement Procedure (MAP) — Article 25 (OECD/UN Model) [S1][S2].
Administrative: Complements Safe Harbour Rules (Rule 10TA–10TG) — reformed recently to improve efficiency and compliance; reduces caseload on Dispute Resolution Panels & ITATs [S1].
Geopolitical: BAPAs are an instrument of tax diplomacy — record BAPAs with USA, UK, Japan etc. signal deepening cooperation; first-ever BAPAs achieved with new partners broaden India's treaty engagement [S1].

31 March 2026: 219 APAs signed in FY 2025-26; cumulative crosses 1,000 [S1].
FY 2024-25: 65 BAPAs signed — previous single-year record (now broken) [S1].
FY 2023-24: 125 APAs signed — earlier annual record [S3].
2025: Government overhauls Safe Harbour Rules to expand eligibility and tighten timelines [S1].

APA programme introduced via Finance Act, 2012 [S2].
Statutory provisions: Sections 92CC (APA) & 92CD (effect of APA), Income-tax Act, 1961 [S2].
APA Rules: 10F to 10T of Income-tax Rules, 1962 [S2].
Programme operationalised on 30 August 2012 via Notification 36/2012 [S2].
Maximum validity of an APA: 5 years (prospective) [S2].
Rollback introduced in Finance (No. 2) Act, 2014 — covers 4 preceding years [S2].
Implementing authority: CBDT under Department of Revenue, Ministry of Finance (NOT CBIC) [S1].
Three types: Unilateral, Bilateral, Multilateral APAs [S1].
FY 2025-26 record: 219 APAs, including 84 BAPAs [S1].
Cumulative APAs since inception (FY 2025-26): 1,034 (750 UAPA + 284 BAPA) [S1].
BAPAs signed in FY 2025-26 with 13 treaty partners [S1].
BAPAs operate through the Mutual Agreement Procedure (MAP) under DTAAs [S1].
Complements Safe Harbour Rules for transfer-pricing certainty [S1].

GS-III — Indian Economy: Mobilisation of resources, government budgeting; Investment models; Ease of doing business.
Syllabus: "Government Budgeting; Effects of liberalization on the economy; Investment models."
Possible question stems: 1. "Advance Pricing Agreements have emerged as a critical tool in reducing transfer-pricing litigation in India." Discuss. 2. Examine how the APA framework, complemented by Safe Harbour Rules, advances India's ease-of-doing-business agenda. 3. Differentiate Unilateral, Bilateral and Multilateral APAs. How do BAPAs strengthen India's tax diplomacy?

APAs are administered by CBDT (direct taxes), not CBIC (indirect taxes).
APA programme started in 2012, not 2009 or 2014; rollback came later in 2014.
Maximum APA tenure is 5 prospective years + 4 rollback = 9 years, not 10.
APAs deal with transfer pricing (international transactions between AEs), not GST or customs valuation.
BAPAs require a DTAA with the foreign country; without it, only UAPA is possible.

[S1] CBDT signs record 219 Advance Pricing Agreements (APAs) in FY 2025–26 — https://www.pib.gov.in/PressReleasePage.aspx?PRID=2247399 — (tier: 1)
[S2] Advance Pricing Agreement (APA) Programme of India — Annual Report (Income Tax Department) — https://incometaxindia.gov.in/Documents/Advance-Pricing-Agreement-APA-Report.pdf — (tier: 1)
[S3] CBDT signs record number of 125 APAs in FY 2023-24 — https://www.pib.gov.in/PressReleasePage.aspx?PRID=2018085 — (tier: 1)