APA & MAP Representation
For a multinational with material recurring flows into or out of India, the arithmetic of an Advance Pricing Agreement is compelling: one negotiated agreement covering up to five future years, with rollback available for four prior years — nine potential audit cycles converted into a single certainty. India's APA programme is mature, actively used, and produces agreements that hold. What it demands is preparation: the application, site visit, and negotiation reward companies that arrive with their economics coherent and their documentation aligned.
We manage APAs end-to-end: feasibility analysis that tests honestly whether an APA serves you better than the audit lottery, pre-filing consultation, application drafting, position papers, site-visit management, and negotiation through to signing and annual compliance. Where double taxation has already crystallised, we pursue Mutual Agreement Procedure relief under India's treaties — coordinating between competent authorities so relief is actually delivered, not merely available in principle.
What this covers
- APA feasibility analysis: expected outcomes, costs, and timelines against your realistic audit exposure.
- Unilateral vs. bilateral strategy — including when treaty-partner involvement strengthens or complicates your position.
- Application preparation, economic analysis, and critical-assumption design that preserves flexibility.
- Site visit and negotiation management through to agreement signing.
- Annual compliance reports and renewal strategy; MAP applications where disputes have already arisen.
Who needs this
Groups with large recurring intercompany flows — captive service centers, contract manufacturers, distributors — and companies already carrying multi-year TP litigation that a rollback could extinguish.
How we deliver
- Feasibility analysis with honest arithmetic: expected position, cost, and timeline against the audit alternative.
- Application, economic analysis, and site-visit preparation run as one project with defined milestones.
- Negotiation through signing, then annual compliance reports for the agreement's life.
Why A2 Consultants
APA negotiation rewards credibility built over years of interaction with the programme — our positions are conservative enough to be believed and precise enough to be negotiated, which is why they conclude.
Engagement & what to expect
APA engagements begin with feasibility: two to three weeks of honest arithmetic on expected outcomes, costs, and timelines against your realistic audit exposure. Where the case is strong, pre-filing consultation and application preparation run over two to four months, followed by the negotiation phase — site visits, position papers, and competent-authority discussions — through to signing. Annual compliance reports continue for the agreement's life. MAP engagements run parallel tracks with treaty-partner authorities where double taxation has already crystallised. Throughout, you hold a single India counterparty accountable for the outcome.
An APA converts your largest recurring tax risk into a known number — for flows that repeat every year, certainty compounds.