India Crosses 1000 APA Milestone as CBDT Signs Record 219 Agreements in FY 2025–26

In a press release issued on 31st March 2026 by the Ministry of Finance, the Central Board of DirectTaxes (CBDT) has signed a record-breaking 219 Advance Pricing Agreements (APAs)in the financial year 2025–26. This brings the growth total of APAs signed since the inception of the programme to 1034, comprising 750 Unilateral APAs(UAPAs) and 284 Bilateral APAs (BAPAs).

The fiscal year also witnessed a historic high of 84 BAPAs, surpassing last year’s record of 65. These agreements were concluded through Mutual Agreement Procedures (MAPs) with 13 treaty partners, including the United States, United Kingdom, Japan, Singapore, and notably, first-time BAPA signings with France, Ireland, Indonesia, and Sweden.

The APA programme, launched to provide certainty in transfer pricing and reduce litigation, continues to be a cornerstone of India’s efforts to improve the ease of doing business. The surge in BAPAs reflects growing international collaboration and confidence in India’s tax administration.

Also read: Income Tax Act 2025: KeyCompliance Changes in Meal Benefits, ITR Filing & PAN Rules

Complementing the APA framework, the Finance Act 2026 has introduced sweeping reforms to the Safe Harbour Rules. Main changes include:

• Consolidation of technology service segments into a unified “Information Technology Services” category with a fixed margin of 15.5%.
• A significant increase in the eligibility threshold from ₹300 crore to ₹2000 crore.
• A shift towards a system-driven, automated compliance model, reducing administrative burden and scrutiny.

The regime currently spans twelve transaction categories, including IT and software services, IT-enabled services, KPO, contract R&D, and intra-group financing. guarantees, auto components, low-value-adding services, and certain transactions in the diamond industry

Together, the APA Scheme and the revamped Safe Harbour Rules offer taxpayers a robust mechanism for advance determination of arm’s length pricing, with BAPAs protecting against double taxation.

Also, the CBDT acknowledged the proactive engagement of taxpayers and emphasised their role as vital stakeholders in the success of the APA programme.