Quick Summary
The CBDT has revamped the Advance Pricing Agreement (APA) framework under the new Income Tax Rules, 2026. The revised regime introduces new Forms 51, 52, 53 and 54, simplified filing procedures, a standardised filing fee structure and faster timelines for unilateral APA processing. The changes are expected to reduce procedural hurdles for multinational enterprises and taxpayers engaged in international transactions with associated enterprises while making compliance easier and more transparent.
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FAQ :
The CBDT has introduced new forms (51, 52, 53, 54), simplified filing procedures, standardised the filing fee to a flat Rs 20 lakh, and set faster timelines for unilateral APA processing.
An APA is an agreement between a taxpayer and the CBDT that determines the transfer pricing methodology for international and specified domestic transactions for a set period, aiming to reduce tax disputes and provide certainty.
New forms include Form 50 for pre-filing consultation, Form 51 for APA applications and rollback requests, Form 52 for annual compliance reports, Form 53 for claim of relief, and Form 54 for APA renewal applications.
The APA filing fee is now standardised at Rs 20 lakh, replacing the previous slab-based system. Additional fees may apply for rollback applications.
Meetings, submissions, and site visits should ideally be completed within one year from the end of the financial year of application. In IT/ITES cases, proceedings may close within two years if no agreement is reached, with a possible six-month extension.
Form 51 combines the previous separate applications for APA and rollback requests into a single form, reducing duplication and paperwork for taxpayers.
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