Multi-year transfer pricing certainty, agreed in advance with the tax authority.
An Advance Pricing Agreement (APA) is a binding agreement between a taxpayer and the Central Board of Direct Taxes that fixes the transfer pricing methodology and arms length range for specified international transactions for up to five future years and four past years through rollback. For groups with material recurring intercompany flows, an APA can convert annual transfer pricing uncertainty into multi-year certainty.
Bizztricks Management Consulting Private Limited supports the entire APA lifecycle pre-filing consultation, formal application, economic analysis, negotiation, and annual compliance reporting under the agreed framework.
What Bizztricks Management Consulting Private Limited Offers
• APA suitability assessment unilateral, bilateral, or multilateral route selection
• Pre-filing consultation with the APA team and case strategy formulation
• Formal APA application preparation under Rule 10F to 10T
• Economic and functional analysis aligned with the negotiating position
• Negotiation support through site visits, technical sessions, and competent authority engagement for bilateral APAs
• Rollback application for the four preceding years under Rule 10MA
• Annual compliance report under Rule 10-O and ongoing monitoring of APA conditions