India-Korea DTAA: Advance pricing agreement with rollback option from Apr 1

The revised treaty with Korea provides for taxpayers to file for bilateral advance pricing agreement, along with rollback provision, for settling transfer pricing disputes from April 2017, the CBDT said today.

had revised the three-decade old Double Taxation Avoidance agreement (DTAA) with Korea in 2015 and the amended pact came into force from September 12, 2016.


In a statement, the today clarified that under the revised treaty beginning April 2017, applications for bilateral Advance Pricing Agreement (APA) involving international transactions with associated enterprises in Korea can be filed along with request for the rollback provision.

“Such requests for the rollback provision shall be processed in accordance with the provisions of the

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