"MAP"ping out a way with US to end TP-disputes - Ambitious or Achievable?

CBDT's recent press release announcing the signing of 2 unilateral Advance Pricing Agreements (APAs), including one with a "rollback" provision, has raised hopes of many a MNCs. CBDT's impressive APA scorecard reads thus - 13 Unilateral APAs & a solitary bilateral APA.  Not only this, the stalled MAP talks with USA, which were revived at beginning of 2015, have got a shot in the arm, with the Revenue announcing that it has resolved about 35 transfer pricing disputes under the Framework Agreement and in what would be music to the ears of US companies, declared its intent to resolve about 100 transfer pricing disputes in the next 3 months and about 200 in the current year, most of them in the IT/ ITES space. CBDT seems committed to provide a tax stable environment to foreign investors, as can be gauged from this major initiative to usher certainty in taxation.

 

Is this significant progress on the APA / MAP front the clearest signal yet of the Government & CBDT's resolve to usher in ‘certainty in taxation’? Is there any room for improvement in the implementation of the successful APA program? Is the target of resolving ‘200’ TP disputes with USA by end of this year through MAP framework, too ambitious a target? Would resolution of MAP disputes with US open the doors for signing bilateral APAs with US and other countries?

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