The Central Board of Direct Taxes (CBDT) on Monday issued a notification clarifying the norms of acceptance of Transfer Pricing MAP cases and bilateral Advance Pricing Agreements (APAs).
The notification by CBDT stated, "Number of references that have been received from time to time regarding the acceptance of applications pertaining to the aforementioned cases, where the Associated Enterprise (AE) of the Indian entity is resident of a country with which India has entered into a Double Taxation Avoidance Agreement (DTAA) but the agreement does not contain Paragraph 2 of Article 9 (or its relevant equivalent Article) of the OECD Model Tax Commentary relating to 'Corresponding Adjustment'."
In its latest notification, the board announced its decision to accept Transfer Pricing MAP and bilateral APA applications regardless of the presence or otherwise of Paragraph 2 of Article 9 (or its relevant equivalent Article) in the DTAAs.
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