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.
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.
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;

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 account of 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, thereby removing the imbalance between cash account and actual profit of the assessee
Secondary adjustment has the meaning given to it in Clause 14.12;
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 is 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. ■ When secondary adjustment will be applicable - Secondary adjustment will be applicable in the following situations −
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.

Related to Secondary adjustment

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

  • Post-Closing Adjustment Amount shall have the meaning set forth in Section 2.4(a).

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

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

  • 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

  • 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.

  • 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.

  • Adjustment Escrow Amount means $2,000,000.

  • Net Adjustment Amount means an amount, which may be positive or negative, equal to (A) the Closing Net Working Capital as finally determined pursuant to this Section 2.5 minus the Estimated Net Working Capital, plus (B) Estimated Indebtedness minus Closing Indebtedness as finally determined pursuant to this Section 2.5, plus (C) Closing Cash as finally determined pursuant to this Section 2.5 minus Estimated Cash, plus (D) Estimated Transaction Expenses minus Closing Transaction Expenses as finally determined pursuant to this Section 2.5;

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

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