Secondary adjustment definition

Secondary adjustment means an adjustment in the books of account of the assessee and its associated enterprise to reflect that the actual allocation of profits between the assessee and its associated enterprise are consistent with the transfer price determined as a result of primary adjustment, thereby removing the imbalance between cash account and actual profit of the assessee.
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Secondary adjustment means an adjustment in the books of accounts of the assessee and its associated enterprise to reflect that the actual allocation of profits between the assessee and its associated enterprise are consistent with the transfer price determined as a result of primary adjustment, thereby removing the imbalance between cash account and actual profit of the assessee. As per the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD transfer pricing guidelines), secondary adjustment may take the form of constructive dividends, constructive equity contributions, or constructive loans.
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Secondary adjustment means the adjustment to demonstrate the extent to which the pricing methodology is consistent with the pricing principles and explain the reasons for any inconsistency between the pricing methodology and the pricing principle, to signal the economic costs of service, recover any shortfall and to compete vigorously with alternative energy sources;
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Examples of Secondary adjustment in a sentence

  • Secondary adjustment Adjustment that arises from imposing a tax on asecondary transaction (that is, a constructive transaction asserted in order to make the actual allocation of profits consistent with the primary adjustment).

  • Otherwise MAP. Thin capitalisation rules not in conflict with Article 9 Secondary adjustment 14/05/2016P.

  • Secondary adjustment shall be required in pursuance to the settlement of disputes It is proposed to be provided that the settling of disputes regarding transfer pricing adjustment would not have any effect on the secondary adjustment, both being independent provisions, and the taxpayer would be required to repatriate fund to India in respect of settled transfer pricing adjustment.

  • Secondary adjustment detailed in Article 10 may be applied only after the application of the primary reference price methodology.

  • Secondary adjustment is, in fact, are adjustments to tax liability that reflect a deemed transaction, therefore it requires a law provision imposing such adjustment.

  • Secondary adjustments in certain cases - New Section 92CE• Secondary adjustment provisions have been inserted in line with OECD Transfer Pricing guidelines and international best practices.

  • Secondary adjustment is required to be made in respect of the said amount, unless Ganga Ltd.

  • Secondary adjustment and computation of interest shall not be required if assessee opts for this option.

  • EXTRA DUTY ASSIGN.- TRS Cook, Secondary adjustment to Yearbook Advisor and WEB Link Crew stipends as a result of leave of absence.

  • It is a bilateral adjustment that modifies the taxable base upward or downward, as appropriate.b) Secondary adjustment 25: The appropriate qualification is given, according to the nature of the income.


More Definitions of Secondary adjustment

Secondary adjustment means an adjustment in the books of accounts of the assessee and its AE to reflect that the actual allocation of profits between the assessee and its AE are consistent with the transfer price determined as a result of primary adjustment.
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Secondary adjustment has the meaning given to it in Clause 14.12;
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Secondary adjustment means an adjustment in BOA of the assessee and its AE to reflect that the actual allocation of profits between the assessee and its AE are consistent with the TP determined as a result of a PA, thereby removing the imbalance between cash account and actual profit of the assessee.
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Related to Secondary adjustment

  • CPI Adjustment means the quotient of (i) the CPI for the month of January in the calendar year for which the CPI Adjustment is being determined, divided by (ii) the CPI for January of 2007.

  • True-Up Adjustment means any Semi-Annual True-Up Adjustment or Interim True-Up Adjustment, as the case may be.

  • Post-Closing Adjustment has the meaning set forth in Section 2.04(b)(ii).

  • Post-Closing Adjustment Amount has the meaning set forth in Section 2.04(c).

  • Purchase Price Adjustment shall have the meaning specified in Section 3.02.

  • Price Adjustment means any and all price reductions, offsets, discounts, rebates, adjustments, and or refunds which accrue to or are factored into the final net cost to the hospital outpatient department or ambulatory surgical center.

  • SOFR Adjustment means 0.10% (10 basis points).

  • Closing Adjustment Amount shall have the meaning set forth in Section 3.2(c).

  • Final Adjustment Amount shall have the meaning set forth in Section 2.5(e).

  • Estimated Adjustment Amount has the meaning set forth in Section 2.8(a).

  • Lot line adjustment means the relocation of the property boundary line in a

  • Closing Adjustment has the meaning set forth in Section 2.04(a)(ii).

  • Adjustment Amount For any Distribution Date, the difference between (A) the sum of the Class A Principal Balance and the Class B Principal Balance as of the related Determination Date and (B) the sum of (i) the sum of the Class A Principal Balance and the Class B Principal Balance as of the Determination Date succeeding such Distribution Date and (ii) the aggregate amount that would have been distributed to all Classes as principal in accordance with Section 4.01(a) for such Distribution Date without regard to the provisos in the definitions of Class B-1 Optimal Principal Amount, Class B-2 Optimal Principal Amount, Class B-3 Optimal Principal Amount, Class B-4 Optimal Principal Amount, Class B-5 Optimal Principal Amount and Class B-6 Optimal Principal Amount.

  • Tax Adjustment has the meaning set forth in Section 4.7.

  • Equity Adjustment means the dollar amount resulting by subtracting the Book Value, as of Bank Closing, of all Liabilities Assumed under this Agreement by the Assuming Bank from the purchase price, as determined in accordance with this Agreement, as of Bank Closing, of all Assets acquired under this Agreement by the Assuming Bank, which may be a positive or a negative number.

  • Purchase Price Adjustment Escrow Amount means $500,000.

  • Adjustment Price means the lowest Underlying Price within the Adjustment Period after the Underlying Price is for the first time equal to or below the Adjustment Threshold.

  • Adjustment Escrow Amount means $1,000,000.

  • Net Adjustment Amount means an amount, which may be positive or negative, equal to the Closing Net Working Capital as finally determined pursuant to this Section 2.9 minus the Preliminary Net Working Capital as set forth on the Preliminary Closing Statement;

  • Related Adjustment means, in determining any LIBOR Successor Rate, the first relevant available alternative set forth in the order below that can be determined by the Administrative Agent applicable to such LIBOR Successor Rate:

  • Term SOFR Adjustment means a percentage equal to 0.10% per annum.

  • Final Adjustment has the meaning set forth in Section 10.3.B(2) hereof.

  • Adjustment Payment shall have the meaning specified in Section 3.09(a).

  • Buy In Adjustment Amount shall have the meaning specified in Section 6.

  • Initial Adjustment Date As to any Adjustable Rate Mortgage Loan, the first Adjustment Date following the origination of such Mortgage Loan.