Unilateral APA in international tax excludes MAP benefits; signed under Rule 10M with government approval.

A unilateral Advance Pricing Agreement (APA) in international taxation involves the Board, with Central Government approval, entering into an agreement with the taxpayer. The agreement is signed by a person authorized to sign the taxpayer's income tax return, following Rule 10M. Once finalized, the Director General of Income Tax (International Taxation) sends a copy to the relevant income tax commissioner. Notably, entering into a unilateral APA excludes the taxpayer from Mutual Agreement Procedure (MAP) benefits for the transactions covered under the APA.

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