Rule 113: Annual APA compliance report in Form 52
Rule 113 requires an annual compliance report for every year covered by an APA. The report is Form 52 and uses a later-of-two-dates filing rule, so the signing date and the relevant return due date both need to be recorded.
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Rule 113 - Furnishing of annual compliance report
(1) The assessee shall furnish an annual compliance report to the Principal Chief Commissioner of Income-tax (International Taxation) for each year covered in the agreement.
(2) The annual compliance report shall be in Form No. 52.
(3) The assessee shall file the annual compliance report for each year covered in the agreement, within thirty days of the due date of filing the income-tax return for that year, or within ninety days of entering into an agreement, whichever is later and send it to Principal Chief Commissioner of Income-tax (International Taxation).
(4) The Principal Chief Commissioner of Income-tax (International Taxation) shall send one copy of annual compliance report to the competent authority of India, one copy to the Commissioner of Income-tax who has the jurisdiction over the income-tax assessment of the assessee and one copy to the Transfer Pricing Officer having the jurisdiction over the assessee.
Rule breakdown
Report for every covered year
The assessee furnishes the annual compliance report to the Principal Chief Commissioner of Income-tax (International Taxation) for each year covered by the agreement.
Maintain a list of all covered years and transactions from the executed APA; do not assume one report covers the entire agreement period.
Use the prescribed Form 52
The rule specifies Form 52. Reconcile its statements with the agreement terms, critical assumptions, supporting data and actual pricing computation.
Keep the evidence supporting the report available for the separate compliance audit.
Calculate both dates and use the later one
The deadline is within thirty days of the return filing due date for the relevant year or within ninety days of entering the agreement, whichever is later.
Use the return due date, not merely the day the assessee happened to file early. Record both calculations and check any valid due-date change before finalising the deadline.
Keep the recipient and circulation roles distinct
The assessee sends the report to the designated Principal Chief Commissioner. That authority sends copies to the competent authority, jurisdictional Commissioner and TPO as specified.
Retain submission evidence. Do not treat the internal circulation described by the rule as a reason to omit the required filing.
Key takeaways
Every covered year
Annual reporting continues throughout coverage.
Form 52
Use the prescribed compliance report.
Later of two periods
Compare thirty days after return due date with ninety days after agreement.
Practical checklist
- List each covered year.
- Calculate both deadline limbs and retain the workings.
- Reconcile Form 52 with the APA and supporting data.
Avoid
- Do not substitute an early actual filing date for the return due date.
- Do not assume signing the APA ends reporting duties.
FAQs
Is there only one compliance report for the entire APA?
No. The rule requires one for each year covered.
Does early return filing itself start the thirty-day clock?
The rule refers to the due date of filing the return, not the actual early filing date.
Which of the two filing periods controls?
The later of the two specified periods.
Glossary
- Annual compliance report
- The Form 52 report required for each year covered by the agreement.