25 … The rules of the APA… Annual Compliance Report: Compliance Audit:date … The rules of the APA… Annual Compliance Report: For each of the years covered by the agreement, the ITD sends a quadruple copy to CA India, the Judicial CIT and a copy to the TPO within 30 days of the expiry date of filing the income tax return for that year or within 90 days of an agreement being reached; According to the compliance audit, the TPO conducts the APA compliance review for each of the annual reviews covered by the agreement, which is required to report within six months of the end of the month in which the annual compliance report was received. However, in the country of related parties (in the case of a unilateral APA), implementation costs are high It is likely that the costs of the APA ≦ review fees. However, the high costs associated with developing the APA application are only economically viable if there is a large volume of transactions. This is evident in the fact that cross-border trade between multinational companies currently accounts for 60% of world trade; Estimates of these figures will reach up to 80% in the coming years. Nevertheless, cross-border trade between multinationals is often uncertain in the areas of customs and TP due to administrative inconsistencies 39 The concept of small capitalization Date The concept of small capitalization Specific rules to prevent small capitalization often require that the debt-to-GDP ratio meet a specific ratio to allow the company to deduct interest expenses. the rules do not specify the debt ratio to claim interest deductions, but a company must guarantee – and, from a transfer pricing perspective, be able to document – that the terms of its intercompany financing are comparable to those it could have received from third-party lenders (for example. B , UK) 13… Map of the APP in India There is currently a parallel mechanism, i.e.