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

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

  • 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.

  • But this is subject to ‘no base erosion’ rule in terms of which if actual income is more than ALP or actual expense is less than ALP, then no adjustment is made since there is no base erosion. Further, after the introduction of Secondary adjustment rules in 2017, the excess amount due to an adjustment in the transaction with an RP is required to be repatriated to India within a prescribed time limit.

  • Secondary adjustment seeks to remove the cash benefit obtained by this Rs. 3 Crore retention and also remove the imbalance between cash account and actual profit.e. This secondary adjustment is in addition to the tax paid/payable by Company X consequent to the adjustment of Rs. 3 Crores.

  • Following points in this regard are worth noting: Nature of payment: Secondary adjustment is triggered once the taxpayer accepts the fact that the transaction undertaken by it has been carried out at a price different from ALP for such transaction, whether as a suo-moto adjustment, or acceptance of AO/ITAT order or under APA, MAP or SHR.

  • TECHNICAL SPECIFICATIONS FOR MICROPIPETTE (PIPETMAN) Measuring capacity 10-100 μ1; 100-1000 μ1 500 - 5000 μ1 Single channeled adjustable volume, dispensing error <±1% Spring loaded tip cone, tight to fit universal tips in each category, ergonomic design Adjustment opening for specific liquids and volume Secondary adjustment for specific liquid.

  • Model Rx [km] Rz/Rx Ry/Rx ρm [g cm−3] MADM [M⊙] Mb [M⊙] J [erg s] T/|W| Pc [ms] Aˆ E˙ [erg s−1]MIT148 14.0 (18.3) 0.457 (0.469) 0.719 (0.728) 5.0 × 1014 1.488 1.636 1.81 × 1049 0.1712 0.955 - 3.51 × 1053MIT265 13.5 (21.9) 0.458 (0.486) 0.781 (0.802) 7.6 × 1014 2.655 3.109 5.23 × 1049 0.1872 0.774 - 8.50 × 1053MIT275dr 14.4 (22.3) 0.313 (0.327) - 5.0 × 1014 2.757 3.121 7.35 × 1049 0.2867 0.705 3.0 -APR206dr 13.8 (19.6) 0.250 (0.260) - 6.0 × 1014 2.060 2.251 3.92 × 1049 0.2599 0.409 1.0 -| |TABLE II.

  • Secondary adjustment to be made by Emsun Ltd.The excess money on account of primary adjustment (ALP) i.e., ` 105 lakhs has to be repatriated by Apollo Inc.

  • The required information must be obtained from the PGAtlas.com website.


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.
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.
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 has the meaning given to it in Clause 14.12;

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.

  • XXXXX Adjustment means, with respect to XXXXX, 0.0326% per annum.

  • True-Up Adjustment means any 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 1.9.3.

  • Purchase Price Adjustment has the meaning set forth in Section 2.6.

  • 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 has the meaning set forth in Section 2.4(c).

  • Estimated Adjustment Amount has the meaning set forth in Section 2.5(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.

  • Spread Adjustment means 100 basis points.

  • 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.

  • SNB Adjustment Spread means, with respect to the SNB Policy Rate, the spread to be applied to the SNB Policy Rate in order to reduce or eliminate, to the extent reasonably practicable under the circumstances, any economic prejudice or benefit (as applicable) to Noteholders as a result of the replacement of the Swiss Average Rate Overnight with the SNB Policy Rate for purposes of determining SARON, which spread will be determined by the Calculation Agent, acting in good faith and a commercially reasonable manner, taking into account the historical median between the Swiss Average Rate Overnight and the SNB Policy Rate during the two year period ending on the date on which the SARON Index Cessation Event occurred (or, if more than one SARON Index Cessation Event has occurred, the date on which the first of such events occurred).

  • Adjustment Payment means, in respect of any Security, the payment (if any) determined by the Determination Agent as is required in order to reduce or eliminate, to the extent reasonably practicable, any transfer of economic value to or from the Issuer as a result of the replacement of the Index by the Alternative Pre-nominated Index. The Determination Agent may determine that the Adjustment Payment is zero.