new delhi as a step towards reducing tax disputes the government today announced apa rules allowing mncs to ascertain in advance their taxation liability in relation to crossborder transactions within group entities the advance pricing agreement apa rules notified by the finance ministry will allow the companies to seek guidance on pricing of goods and services in advance for calculating taxes under the transfer pricing mechanism about rs 60000 crore is locked up in litigation on account of dispute over pricing of crossborder movement of goods and service within the group companies these transactions have a bearing on the tax liability according to a global financial integrity report major channel of illicit outflow is transfer of funds through mispricing tax disputes arise because of differences in costing of the goods and services which are transferred between different nations with the new rules there would be apa for multiple years between a taxpayer and central board of direct taxes cbdt on an appropriate transfer pricing methodology for a set of international transactions though the provision for apa was included in the direct taxes code dtc bill the centre has brought forward its implementation by including it in finance bill 2012 once the company enters into an agreement it is absolved from the future litigation and also lot of compliance procedures senior director deloitte india mudigonda vishweshwar said a company which is proposing to enter into an apa has to necessarily attend a prefiling consultation with the cbdt however firms have been given option to remain anonymous during preconsultation stage if they do not want to share all the details initially with tax authorities prefiling consultation would help the companies to understand the approach to be adopted by authorities actually before entering into the agreement vishweshwar said vijay iyer partner with ernst young said the muchawaited rules will provide greater clarity to taxpayers on the apa programme he said the apa regime is a big positive and a big step towards creating an environment of resolution of disputes fee for entering into apa would be rs 10 lakh for transaction up to rs 100 crore rs 15 lakh for those up to rs 200 crore and rs 20 lakh for transactions above rs 200 crore