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Advance Pricing Agreement survey report 2017

KPMG.com/in

May 2017

Transfer Pricing

The Advance Pricing Agreement (APA) programme launched in 2012 in India promised a significant mitigation of tax uncertainty arising from Transfer Pricing (TP) disputes, by offering an alternate dispute resolution mechanism. Since then the programme has received an overwhelming response with 815 applications filed and 152 agreements signed as of 31 March 201701.

KPMG in India’s 2017 APA survey offers key insights and observations from taxpayers as well as from the tax department, as the programme is about to complete 5 years. Being the first survey collating an all-rounded perspective, the findings of the survey indicate that the APA programme has largely met taxpayers’ expectations so far.

The taxpayer respondents have lauded the rational and pragmatic approach of the Indian APA authorities. While the first-ever APA Annual Report issued by the Central Board of Direct Taxes (CBDT) for 2016-17 indicates that the disposal timelines in India are better than that achieved by most countries having APA programme for long, our survey findings indicate that the applicants expect a faster resolution rate, stronger administration, increased resources and clarity around certain complex issues related to or incidental to the APAs.

The CBDT’s responses to our survey highlight the need for the applicants to respond to the queries of APA authorities in a time bound manner as well as being transparent and collaborative to share relevant information pertaining to the large Multinational Enterprise (MNE) group.

We are thankful to CBDT and the taxpayers to have responded to our survey. We hope you find the survey report useful and insightful.

01. APA Annual Report 2016-17 issued by the Central Board of Direct Taxes released on 01 May 2017

KPMG in India was awarded the Transfer Pricing Firm of the Year 2017 by International Tax Review

© 2017 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

Girish Vanvari Partner and Head Tax KPMG in India

Rahul K MitraPartner and HeadTransfer Pricing and BEPSKPMG in India

• KPMG in India’s APA Survey 2017 charts the evolution of the APA program in India.

• The selected findings in this report are based on survey of respondents comprising senior level personnel responsible for finance, accounts and taxation of companies across major industry sectors.

• The respondents comprised the taxpayers who have already applied for an APA as well as those who have not applied but may be interested in the program.

• To help ensure an all-rounded perspective, we also requested the CBDT to provide their inputs on the survey.

• Apart from the survey findings, this report also captures relevant factual data from the APA Annual Report (2016-17) released by CBDT* as well as from other credible sources.

About the survey

Note:

* The APA Annual Report issued by the CBDT for (2016 -17) will hereinafter be referred to as APA Annual Report (2016-17)

© 2017 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved

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Table of contents

Measuring performance

Process efficiency

What impacts APA

outcome

10

11

Implementation aspects

Unilateral vs Bilateral

APAs

India’s APA programme –progressive 5 yearsThe Advance Pricing Arrangement (APA) programme commenced in India in 2012, allowing a much needed alternate dispute resolution mechanism for Transfer Pricing (TP) disputes. From the first year ofits introduction, the programme set benchmarks in proactive resolution of tax disputes and promisedlong-term tax certainty. With 815 applications filed and 152 APAs signed till 31 March 2017, theprogramme has seen constant evolution and success albeit in a short period of time.

Given the continued significant relevance of the programme, we carried out a survey to look back at last 5years of the programme in terms of its process, implementation, performance, administration, outcomes and the future outlook. To evaluate these aspects from a holistic perspective, KPMG gathered responses from taxpayers as well as CBDT, making it the first-ever survey of its kind.

Why APAs

Type of transactions taken to APA

Our survey indicates the predominant categories

of transactions for which APA was preferred by

our respondents.

The programme started in 2012 in the backdrop of incessant TP litigation and tax uncertainty. The survey findings reaffirm the same, as respondents voted for their primary reasons for opting APA.

The survey also affirms that the APA programme reduces the documentation/ compliance/ litigation burden on the taxpayers.

50%

10%

3%

40%

10%

Avoid double taxation 19% Applicants

Complexity of transactions

Volume of transactions Non applicants

Avoid incessant litigation 84%

Achieve certainty 79% Yes No

Trading, import/export

Services (IT,ITeS, BPO, KPO)

Management cross charges

Royalty

92% 8%

85% 15%

AMP/ Marketing intangibles

The APA Annual Report (2016-17) also indicates

the predominant categories of transactions for

which APAs have already been signed.

54%

Royalty

Other transactions

Financial transactions

Intra group payments

Trading, sale/purchase

Services

While the 152 APAs concluded so far cover diverse categories of transactions, the transactions related to

provision of services (IT, ITeS, business support and others) constitute a predominant part of those. Our

survey results however indicate that transactions involving non-service transactions or complex issues,

that constitute significant segment of the APA programme, are still in the pipeline.

23%

27%

5%

8%

11%

19%

2%


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Source: APA Annual Report (2016-17). The nature of transactions covered data provided in section B.7 of the report has been summarised by us in major key categories as depicted above

These were multi choice questions where the participants had the option to choose more than one response.


MeasuringperformanceMajority of our survey participants were satisfied with the programme.

While the primary focus areas for taxpayers to opt for APAs was to avoid incessant litigation and achieve certainty, our survey looked into key areas related to the taxpayers’ expectations from the programme.

The participants were asked to provide satisfaction ratings across several parameters measuring whether their overall expectations from the programme were met so far. These parameters include –

Rationality and pragmatism of the approach

Capability of the APA team

Time frame and efficiency in conclusion of APAs

Satisfactory resolution of complex issues

Effectiveness and clarity in the APA legislative framework

The survey results discussed further in the report show that the applicants strongly agreed that APAs would lead to a reduction in the compliance/litigation burden. While this augurs well for the future of the APA programme in India, the survey respondents expect improvement in the time frame and efficiency in the APA process.

The APA authorities have been appreciative of the commercial and business realties of taxpayers in unique situations when presented with appropriate justifications.

APA team – expertise

The APA team has adequate experience and is technically equipped to handle the complex APA application forms filed by taxpayers.

APA team – bandwidth

The APA team has adequate bandwidth/manpower to deal with pending cases.

Yes 68%

No 32%

Yes 73%

No 27%

Yes 38%

No 62%

Pragmatic approach

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Timelines and efficiency – have taxpayers’ expectations been met?

Since the introduction of the programme a total of 815 APA applications have been filed (both unilateral and bilateral). With 152 APAs signed till 31 March 2017 and 19 applications disposed-off for other reasons, the current pipeline has 644 application pending in the programme, reflecting about a 79 per cent pendency rate.

2012-13 68 12 66

2013-14 66 5 161

2014-15 15 190

The APA Annual Report (2016-17) indicates that majority of the 152 signed APAs were concludedin the last 24 months, making FY2016-17 as the first benchmark year wherein 88 APAs wereconcluded, probably the highest number of APAs entered into by any jurisdiction world-wide inthe same period. With the volume of APAs India has, new benchmarks are likely to be set in thefuture.

The APA Annual Report (2016-17) also indicates that average processing time so far for unilateral APAs is about 29 months and for bilateral APAs is about 39 months. While these timelines may be better than those reflected by certain matured APA programmes worldwide as claimed by the report, there are apprehensions that the average disposal time period may increase due to major backlog for earlier years.

As indicated here, the pending cases for FY12-13, FY13-14 and FY14-15 currently constitute almost 65 per cent of the total 644 applications currently under processing, and have spent nearly 24 to 48 months already in the pipeline so far.

However, given the experience and best practices alreadygathered by the APA team in the last 5 years, the disposal may get faster, particularly for cases involving similar issues as have been dealt in 152 APA already signed.

Our survey asked whether the APA

programme has been progressing as per

a reasonable time frame in line with

taxpayer expectations?

Just over half of the survey respondents

expressed satisfaction with the timelines,

identifying this to be an area that possibly

has an expectation gap.

2015-16 128

2016-17 99

0 50 100 150

Disposed off other reasons

200 250

APA signed Pending

Yes 51%

No 49%

YearPending cases

% of total applications filedduring the year

Time spent in-process till 31March 2017

FY12-13 66 45% 48 months or more



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Respondents’ observations on improvement areas for the programme

“The authorities need to have more power to close complex issues and take a pragmatic stand

in deserving cases”

“Increase in bandwidth of the APA team and involvement of experts so that taxpayers get early

relief and quicker results”

“APA authorities should be more flexible to understand the business dynamics and future

economic conditions”

CBDT’s perspective

While taxpayers feel the need for faster resolutions, the tax department feels that the APA programme in India is progressing at commendable speed.

CBDT’s responses to key survey questions

Do you feel that the APA programme has progressed as per the expectations of applicants and is

in line with the time taken by tax administrations globally?

“India is doing better than many other countries in terms of the time taken to conclude APAs.

Statistics reveal that the average time taken by India is less than what U.S. or China are

taking. For example, in 2016, the average time taken by U.S. to resolve bilateral APAs was 51

months while India has taken about 39 months to resolve such APAs”

With a large number of APA applications pending conclusion, does the Board have any expansion

plans or any other plans for expediting the APA process?

“The government has already quickened the approval process. Manpower requirements of

the APA Programme are also being addressed.”

How are APA officers being empowered/trained to improve their skill sets and knowledge base?

International trainings, exposure to international tax practices and internal instructions/circulars

and discussion.

The APA rules provide for the inclusion of experts in statistics, economics, law or any other field.

However, until now we have not seen the appointment of such experts. What could be the reason

for the same?

The current APA team is well equipped to handle all kinds of cases.

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Key takeaways The APA programme in India has witnessed a rapid evolution since its introduction in 2012. The

significant volume of applications filed year after year shows taxpayers’ trust and appreciation of

the programme and the capability of its administration. The taxpayers have also applauded the

way in which a number of complex TP issues, which have witnessed protracted litigation, are

being increasingly resolved through the programme.

Unlike other economies such as the U.S., the U.K. etc. where similar programmes may have

commenced in a progressive manner while achieving greater maturity every year, India’s APA

programme started with a big-bang which explains the reason that despite a better disposal rate

in India vis-à-vis what most countries have achieved, the applicants expect even faster resolution

from the APA authorities.

The backlog of APA cases may start swelling up as the renewal application would also start by

the end of current year. The APA administration should expand its resources to continue its

successful track record. CBDT has acknowledged in the APA Annual Report (2016-17) the

challenges around availability of trained manpower, and other human and physical resources,

required to expand and strengthen the programme.

The applicants can also help progress the programme efficiently by responding to various queries

of the APA authorities in a time-bound manner.

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Process efficiencyBroadly an APA process comprises of the following steps:

1. Pre-filing consultation

2. Filing of the APA application

3. Due diligence and site visit conducted by the APA team

4. Post site-visit discussions and negotiations

5. APA team prepares draft position paper for approval by the CBDT

6. Final negotiations and drafting of APA agreement

7. Signing of APA

We attempted to gauge the participants’ experience across the APA process.

Participants were asked to provide their inputs about the APA process including their experience on effectiveness of pre-filing consultations, relevance and quality of information sought by the APA authorities and their focus areas while getting APAs finalised.

Most of the participants reported positive experience with the APA process and indicate certainty of tax flows for future as well as rollback years as the focus area while finalising the APA terms. While the survey results demonstrate a sense of satisfaction among the applicants, the CBDT in their response indicate that taxpayers should be more transparent andforthcoming in sharing the information and adhereto timelines.

Pre-fi l ing consultations

When the APA regime was newly introduced in India, pre-filing consultations were a useful tool for the prospective applicants to assess the chances of their success in the APA programme and also get themselves familiarised with the nuances involved.While the pre-filing consultations were mandatory when the program began in 2012, this step was made optional in March 2015.

In our survey we assessed whether respondents opted for a pre-filing consultation.

Yes, 83%

We also assessed the relevance of pre-filingconsultations and whether such discussionsmet the expectations of taxpayers.

Partially met, 23%

While most of the respondents expressed satisfaction with the level and quality of discussions they had during pre-filing consultations, the relevance of this step seems limited to cases that involve complex transactions.

“Pre-filing consultation was compulsory inthe initial years. Out of such pre-filing consultations, more than 90 per cent wereon an anonymous basis. After suchconsultations were made optional, theyhave been few and far between.”

- CBDT’s response to our survey

No, 17%

Met, 68%

Not met, 9%

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The CBDT expressed their concern on overwhelmingly large number of new applications being filed in the month of March each year.

“The phenomena of an overwhelmingly large number of new applications being filed in themonth of March every year creates administrative challenges and requires diversion ofmanpower from processing of old applications to verification of the new applications filed. Itwould be better if applicants can file applications throughout a year instead of pushing them tothe end of the year.”

Due diligence and information request

The APA authorities spend considerable time in understanding the unique business realities, commercial complexities and the underlying data provided by the applicants during an APA process. During this part of the process, the APA authorities expect applicants to be transparent and forthcoming in sharing the information in a timely manner. The taxpayer’s perspective is to ensure that requested information is relevant and useful and not based on a one-size fit-all approach.

Our survey attempts to assesses this aspect from both the sides.

Applicants’ perspective

Satisfied with the quality of discussions

Requested information was relevant?

The applicant respondents also provided their comments in our survey appreciating the proactive and positive approach of the APA authorities.


In response to our survey, the CBDT did express certain concerns with the quality and timeliness of information shared by the applicants. Specific inputs from the CBDT relate to non-adherence of timelines by the applicants and non-sharing of information relating to the larger MNE group.

No, 23%

CBDT in their response also mentioned that

Both sides – taxpayers and theAPA authorities – need to work incloser collaboration in respect ofsharing of information.

Many applicants are very slow inresponding to the queries issued bythe APA authorities. This delays theentire process and needs to beaddressed by the taxpayers.

Yes, 80%

No, 20%

Yes, 77%

07


In response to our survey question asking of particular procedural issues that have been more difficultto deal with, CBDT responded that

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What impactsAPA outcomeAPA is an alternate dispute resolution mechanism. The complexity and multitude of transfer pricing disputes and the limitations of traditional litigation forums to handle such fact- intensive matters triggered the need for alternate dispute resolution mechanism. While the Mutual Agreement Procedure (MAP) has been in existence for many years, it too has certain limitations.

The APA programme right since its inception isregarded as a mechanism which allows thetaxpayers to provide their inputs in a morequalitative and open manner.

Majority of the taxpayers who preferred for an APAhave had certain litigation history and relatedprecedence at various levels. To assess whether anysuch historical precedence in the applicants’ owncase has had any impact on the APA process, weasked both the applicants and the CBDT in oursurvey whether the following factors are relevantduring an APA negotiation.

Arm’s length price (ALP) proposed by the tax authorities for earlier years during TP audits

ALP prescribed under Safe-Harbour norms

Outcome of litigation proceedings

MAP settlement have a bearing on the ALPnegotiated under the APA.


In response to our survey, CBDT didindicate that while safe-harbours and prioryear TP audit outcomes do not have muchbearing on the APA process and its expected outcome, other historical precedence such as MAPs and orders at Tribunal and High Court levels do impact the APA outcome. The level of impact of various factors on the APA authorities during negotiations is tabulated as under.

Applicant’sperspective

In response to our survey, the respondentslargely indicated that historical precedence aswell as safe-harbour norms impact the APAoutcomes. The results of survey indicate thefollowing.

Impact of TP audits and Safe-harbours

Impact of MAP and historical litigation(ITAT/High Courts) outcomes

Yes, 42%

Yes, 58%

No, 58%

No, 42%

Applicants

Non-applicants

Yes, 53%

Yes, 63%

No, 47%

No, 37%

Applicants

Non-applicants

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Key takeaways While many taxpayers are of the view that the historical TP audits and the Safe Harbours do impact

the outcome of APA, the response from the tax department seems to allay the fear as the prior

years’ TP outcomes and Safe Harbours are considered of least importance by the CBDT.

Safe Harbours are considered as ’convenience benchmarks’” not reflective of any actual functional

analysis or of an arm’s length benchmark. Therefore, Safe Harbours should not influence the APA

outcome. Nevertheless, in applicable cases, they may indicate an upper limit to assess the

reasonableness of APA outcome.

The importance of historical orders of Tribunal/ High Court, MAP outcomes and bilateral APAs entered

into by the counter country has been underscored by the CBDT as well as by the taxpayers.

The taxpayers would however expect that the APA process, being open, transparent and consultative,

would differentiate historical litigation outcome from the APA in necessary cases. The litigation

precedence should have limited or no relevance in cases involving change in facts, change in business

model or change in functional analysis.

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ImplementationaspectsEven though the APA programme in India has completed five years, there are still some aspects on which taxpayers require clarity.

In our survey, we asked the respondents whether they have sufficient clarity on the following aspects related to implementation of APA.

Impact of APA and rollback on grant of tax

holiday benefits

Impact of APA in Minimum Alternate Tax

computations.

Tax holiday benefits

Have you obtained clarity on impact of grant of tax holiday benefits for the APA period (viz. for rollback and APA period going forward) under the APA programme?

Minimum Alternate Tax (MAT)

Have you obtained clarity on the impact of MAT in case of concluded APAs?

Survey respondents said, "more awareness should be created at the level of Commissioner of Income Tax and Assessing Officer who have very less idea about the APA programme, which in turn causes delays in giving refunds for the assessment years under APA rollback."

Yes, 53%

No, 47%

Yes, 47%

No, 53%

Key takeawayThe survey has indicated that many taxpayers,

while finalising their APA terms, did not get clarity

on certain pertinent issues including the impact of

APA on tax holiday benefits and MAT computation.

Since these issues are vital from the taxpayer’s

perspective to get certainty on tax outflows, the

CBDT can perhaps consider providing guidelines

on such issues by way of public circulars.

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Unilateral vs.bilateral APAsThe APA programme in India allows filing of unilateral, bilateral and multilateral APAs. As per the clarification provided by the CBDT, for filing bilateral/ multilateral APAs, presence of Article 9(2) of the OECD Model Convention in the DTAA of the country with which such BAPA/ MAPAs are proposed to be entered into is specifically required. This and the non-acceptance of bilateral APA applications in the U.S. till 2016 filing, for cases involving India transactions has resulted in significantly lower number of bilateral APAs as compared to unilateral APAs.

However, over the last 12 months certain developments have pushed forward the filing of new bilateral applications and conversion of existing unilateral APA into bilateral. The DTAAs with countries such as Singapore and South Korea now include model Article 9(2), opening doors to the taxpayers for filing bilateral APAs. Further, after successful resolution to a large number of U.S.-India MAPs, the U.S. APA office has started accepting bilateral APA applications with India.

In our survey, we asked the respondents whether they would prefer a bilateral APA and if not the primary reasons thereof.

Statistics so far

Up till 31 March 2017, 815 APA applications have been filed, comprising 706 unilateral applications and 109 bilateral applications. No multilateral APA has been filed so far.

After conversions (of unilateral into bilateral and the other way around), the position as of 31 March 2017 is depicted below.

Out of the above applications, 152 APAs have been signed till 31 March 2017, comprising of 141 unilateral APAs and 11 bilateral APAs.Out of 11 bilateral APAs, 5 have been signed with Japan and 6 with the U.K.

Absence of model Article 9(2) from many treaties and non-acceptance of India bilateral APA by the U.S. till Jan 2016 led to no bilateral APA resolution with the U.S. or other countries. However, as indicated before, there have been significant developments in the last 12 months. In fact as per a press release by the CBDT dated 17 November 2016, terms and conditions of the first ever Bilateral Advance Pricing Agreement (APA) involving India and the U.S. have been agreed upon within a short span of eight months, after the U.S. started its bilateral process with India in February 2016 by starting to accept applications from the U.S. taxpayers.

The APA Annual Report (2016-17)discloses that the U.S., U.K. and Japan are the top 3 jurisdictions for bilateral APA accounting for a total of 98 applications.

11

84%

16%

688

Unilateral

Bilateral

108

Bilateral - converted

from unilateral

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Survey results - preference for unilateral APAs

When asked about the reason for significantly large number of unilateral APAs having been filed as against bilateral APAs, the respondents cited resolution in a shorter time frame as the major reason for filing unilateral APAs in preference to bilateral APAs. Another major reason for opting for a unilateral APA is existence of transactions with associated enterprises in multiple jurisdictions.

Survey results - recommendation for unilateral vs bi lateral

When asked which type of APA programme would they recommend to other companies given their experience, the respondents again favoured significantly towards Unilateral APA.

Key takeaways The number of APAs signed till 31 March 2017 (141 unilateral and 11 bilateral) indicates optimism

for the future. The process can be further expedited with the taxpayers adhering to timelines, the

APA authorities addressing manpower requirements and the CBDT issuing guidelines on critical

issues concerning implementation aspects. Bargaining, though part of negotiation, would yield

better results if based on principles and not just the positions.

No multilateral APA has been filed because of the onerous task of negotiating with multiple

competent authorities. However, in case of affiliates in multiple jurisdictions, bilateral APA (with key

affiliate) can be opted. The survey however has shown preference for unilateral APAs due to lesser

time and resource requirement. In high stake cases or where the tax treaty with counter party has

Article 9(2), relating to corresponding adjustment, bilateral APA, which would be tax neutral for

group as a whole, may be preferred.

Resolution in a shorter time frame 79%

Transactions with multiple Associated Enterprises (AEs) in different jurisdictions

23%

Absence of correlative relief underthe tax treaty, hence bilateral APAnot feasible

8%

No APA regime in the other country

6%

Yes, would recommend unilateral APA with rollback

47%

Yes, would recommend unilateral APA without rollback

12%

Yes, would recommend bilateral APA with rollback

24%

Yes, would recommend bilateral APA without rollback

2%

No, would not recommend 15%

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Based on the survey results as well as the APA Annual Report 2016-17, released by the CBDT, the APA programme seems to have contributed significantly towards achieving tax certainty. However, this would seem to be an ongoing process as TP would continue to be seen as a key tax risk area, as several countries including India implement the TP recommendations arising from the Organisation for Economic Co-operation and Development’s (OECD) Action Plan on Base Erosion and Profit Shifting (BEPS).

In our survey, we asked the non-applicant respondents to comprehend their perspective for not opting for the APA programme and their future outlook.

Most respondents cite insignificant TP adjustments as one of the primary reasons for not opting for an

APA. The rationalisation measures related to TP law implemented in India over the last 2 years and the

risk-based TP scrutiny selection norms may have contributed to the same

Future outlook• With BEPS action items now being implemented in India and the concept of secondary adjustment

introduced by the Finance Act 2017, there are likely to be new issues and litigation risk areas on the

horizon.

• Unfavourable litigation outcomes are also expected to make the APA programme suitable as an

alternate dispute resolution mechanism.

• The survey results indicate that avoidance of double taxation, complexity of transactions and new

transactions are also likely to be the major reasons for filing APAs in the near future. Given the BEPS-

related developments, taxpayers would need to align their global TP policies, which may result in

newer and more complex transactions requiring an upfront certainty by way of an APA.

• The proportion of bilateral APAs may also increase as being more effective in resolving double

taxation and transactions involving complex structures and contentious issues.

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Future outlook

Key reasons for not opting APA Key reasons to file APA in near future

58%

33%

21%

21%

21%

8%

Achieve certainty

Avoid incessant litigation

Entering into new transaction(s)

Complexity of transaction(s)

Avoid double taxation

Volume of transaction(s)

No/insignificant TP adjustment for the earlier years 47%

Not convinced of the merits of the APA 24%

Limited internal resources who could provide support in APA

16%

Cost of APA outweighs the benefits 15%

Relief can be obtained in appellate proceeding 15%

Entering into an APA and going through an audit will have the same outcome

8%

Routine litigation is a simpler and a lower cost alternative

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The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

All views and opinions expressed herein are those of the survey respondents and do not necessarily represent the views of KPMG in India.


The KPMG name and logo are registered trademarks or trademarks of KPMG International.

This document is meant for e-communications only. (001_SUR0517)

Mritunjay KapurPartner and Head Sales and MarketsT: +91 124 307 4797E: [email protected]

Girish VanvariPartner and Head TaxT: +91 22 3090 1910E: [email protected]

Rahul K MitraPartner and HeadTransfer Pricing and BEPST: + 91 124 307 4524 E: [email protected]

Ajay Mehra Partner and HeadTax Sales and Markets T: +91 22 3090 2701E: [email protected]

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