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Article · 6 August 2026 · Academy of Tax Law

India's APA programme annual report highlights reforms under new tax legislation

Transfer PricingAdvance Pricing AgreementsIndiaSafe HarbourMAP

India's Income Tax Department has published the Advance Pricing Agreement Programme Annual Report FY 2025–26, dated July 2026. The report covers the performance, statistical analysis and operational outcomes of India's APA and Mutual Agreement Procedure programmes for the financial year.

The report also addresses APA reforms introduced under the Income Tax Act 2025 (Section 168) and the Income Tax Rules 2026 (Rules 103 to 120), both of which took effect on 1 April 2026. Safe harbour rule reforms are also noted, though the source material does not set out the detail of those changes.

Practitioners advising on Indian transfer pricing matters should review the full report for programme statistics and guidance on how the new legislative framework applies to APA applications going forward.

Primary sources