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Rules 2026 · Rule 110

Terms of the agreement (advance pricing agreement)

Rules 77-130

Rule 110 lists what an advance pricing agreement may contain and says the agreement stops binding the Board or the assessee if a critical assumption changes or conditions are not met, with notice by both sides, and revision or cancellation under rules 115 and 116.

What it may include (sub-rule 1). The international transactions covered; the agreed transfer pricing methodology; the arm's length price, if any, and how it is determined; definitions of terms used in those; critical assumptions; rollback provisions under rule 111; and any conditions beyond the Act and these rules.

When it stops binding (sub-rules 2 to 4). The agreement is not binding on the Board or the assessee if a critical assumption changes or a condition is not met. The binding effect ceases only if a party has given due notice to the other party or parties. In that case the agreement may be revised or cancelled.

Notice (sub-rules 5 and 6). The assessee gives written notice of the change or failure to the Principal Chief Commissioner of Income-tax (International Taxation) as soon as practicable; the Board gives the assessee written notice as soon as it learns of it. Revision and cancellation follow rules 115 and 116 (sub-rule 7).