India publishes its seventh APA Annual Report for FY 2024-25

In brief

The Central Board of Direct Taxes (CBDT) has published the seventh Annual Report¹ on the Indian Advance Pricing Agreement (APA) programme (APA Report), capturing outcomes for the financial year (FY) 2024-25. Backed by taxpayers’ increasing support and confidence, the APA programme’s momentum remains strong, with the total number of signed APAs reaching 815 as of 31 March 2025. 

Key marquee achievements of the APA programme from FY 2024-25 include: 

• Record APA signings in a single year since the inception of the APA program with 174 signed APAs, a 39% increase from last year.

• Highest yearly APA signings by any country in a tax year (based on public reports from leading jurisdictions).

• India’s first Multilateral APA (MAPA) signed in FY 2024-25.

• Maximum Bilateral APAs (BAPAs) and Unilateral APAs (UAPAs) signed in a year with 65 BAPAs and 109 UAPAs signed in FY 2024-25, bringing the cumulative total to 200 BAPAs and 615 UAPAs.

• Renewals comprised half of the signed APAs with 98 out of the 174 APAs being renewal cases (27 BAPA renewals and 71 UAPA renewals), reflecting taxpayers’ trust in the APA programme.

• Pending APA inventory remained constant at 858 APA applications as of 31 March 2025, comprising ~42% of the total cumulative APA applications.