- India signed a record 219 Advance Pricing Agreements in FY 2025–26, surpassing all previous annual performance benchmarks.
- The cumulative total surpassed 1,000 agreements for the first time, signaling a shift toward tax certainty.
- India expanded its international reach by signing first-ever bilateral APAs with France, Ireland, Indonesia, and Sweden.
(INDIA) — India’s Central Board of Direct Taxes signed 219 Advance Pricing Agreements in FY 2025–26, taking the cumulative number of agreements since the programme began to 1,034 and setting a new annual record.
The milestone, announced in a Central Board of Direct Taxes press release dated 31 March 2026, marks the first time the total number of APAs has crossed 1,000. It also points to a tax framework that has moved toward certainty rather than prolonged disputes.
The 219 agreements signed in FY 2025–26 exceeded the previous annual high of 174 APAs in FY 2024–25. Within the cumulative total of 1,034, the Central Board of Direct Taxes counted 750 Unilateral APAs and 284 Bilateral APAs.
That annual increase was driven in part by a surge in bilateral deals. India signed 84 BAPAs in FY 2025–26, the highest such yearly figure so far and above the previous record of 65.
Those bilateral agreements were concluded through Mutual Agreement Procedures with 13 treaty partners. The countries named among them were the United States, United Kingdom, Japan, Singapore, Finland, South Korea, Australia, Denmark, and New Zealand.
India also signed its first-ever BAPAs with France, Ireland, Indonesia, and Sweden. The addition of those countries widened the reach of the programme and reflected broader international tax cooperation.
Advance Pricing Agreements sit at the centre of transfer pricing administration for multinational enterprises engaged in cross-border transactions. In the Central Board of Direct Taxes’ account of the programme, the expansion means fewer tax disputes, lower compliance costs, and greater visibility on tax liabilities for those companies.
That shift matters because the agency presented the programme as part of India’s move away from a litigation-heavy tax regime. The crossing of the 1,000-agreement mark, along with the record annual total, was framed as evidence of a certainty-driven framework taking shape.
The scale of growth has been sharp over time. The programme moved from five agreements in FY14 to 219 in FY26, a rise that the Central Board of Direct Taxes said showed the tax administration’s ability to handle complex transfer pricing negotiations at scale.
The composition of the cumulative total also shows how the programme has developed across both domestic and cross-border cases. Unilateral APAs still make up the larger share, but the strong rise in Bilateral APAs indicates deeper engagement with treaty partners through Mutual Agreement Procedures.
That bilateral expansion stands out because BAPAs often require coordination beyond one tax authority. The FY 2025–26 total of 84 BAPAs, reached through Mutual Agreement Procedures with 13 treaty partners, placed that part of the programme at a new high.
For multinational groups, that matters in practical terms laid out by the agency. The Central Board of Direct Taxes said the system gives companies greater visibility on tax liabilities while cutting down the chances of disputes and trimming compliance costs.
The record number for FY 2025–26 also built on momentum from the prior year rather than arriving in isolation. The previous high of 174 APAs in FY 2024–25 had already set a benchmark, and the latest figure pushed that pace further.
India’s first bilateral agreements with France, Ireland, Indonesia, and Sweden added another layer to that momentum. Those first-time pairings expanded the roster of countries with which India has concluded bilateral pricing arrangements.
The named treaty partners underline the breadth of the network involved in the programme. Alongside the United States and United Kingdom, the list included Japan, Singapore, Finland, South Korea, Australia, Denmark, and New Zealand.
In tax administration terms, the numbers suggest a system that has broadened both in volume and in diplomatic reach. The overall tally of 1,034 agreements combines 750 Unilateral APAs with 284 Bilateral APAs, showing growth on both tracks.
The Central Board of Direct Taxes did not present the milestone simply as a numeric achievement. It tied the result to a wider effort to replace a dispute-heavy approach with one built around certainty, especially in matters involving transfer pricing.
That framing is central to why Advance Pricing Agreements have drawn attention from multinational enterprises. When companies have clearer visibility on tax liabilities in cross-border transactions, they face fewer areas of uncertainty in planning and compliance.
The Bilateral APA count is particularly notable because those agreements involve treaty-based engagement through Mutual Agreement Procedures. Reaching 84 in a single fiscal year, while also opening first-ever bilateral agreements with four new countries, pointed to a broader capacity for international coordination.
The annual record also sharpened the contrast with where the programme began. Moving from five agreements in FY14 to 219 in FY26 showed a tax administration handling a much larger volume of negotiations than in the early years.
That rise came as India expanded from a smaller pool of APA outcomes into a system with more than 1,000 cumulative agreements. The Central Board of Direct Taxes cast that as a marker of maturity in the programme.
For companies operating across borders, APAs can alter the tenor of tax administration by setting terms in advance rather than leaving issues to later disputes. The agency’s summary of the programme stressed exactly those effects: fewer tax disputes, lower compliance costs, and more visibility on liabilities.
The bilateral side of the programme also shows where treaty relationships are becoming more active. Mutual Agreement Procedures with 13 treaty partners produced the latest group of BAPAs, including the first ones with France, Ireland, Indonesia, and Sweden.
That matters because expansion into new jurisdictions can reshape how multinational enterprises assess transfer pricing certainty across markets. The addition of new treaty partners in concluded Bilateral APAs broadens the programme’s international footprint.
Even so, unilateral agreements remain the larger block in the cumulative figures. Of the 1,034 APAs signed since the programme’s inception, 750 were Unilateral APAs, while 284 were Bilateral APAs.
Still, the pace of Bilateral APA growth in FY 2025–26 stood out within that wider picture. The 84 agreements reached in the year were not only above the prior year’s 65, but also marked the highest annual bilateral total on record.
The Central Board of Direct Taxes released the figures on 31 March 2026, closing the fiscal year with both a record annual result and a symbolic threshold. Crossing 1,000 Advance Pricing Agreements gave India’s tax administration a measurable sign of how far the programme has moved from five agreements in FY14 toward a system built on certainty, treaty coordination, and complex transfer pricing negotiations at scale.
