The concept of secondary adjustments was introduced vide. Finance Act of 2017, by way of insertion of Section 92CE, as yet another initiative to align Indian transfer pricing norms with internationally accepted practices. Recently, CBDT notified new Rule 10CB in the Income tax Rules, 1962 in relation to secondary adjustments which prescribe the time limit for repatriation of excess money and methodology for computation of interest income. Rakesh Nangia, Managing Partner and Amit Agarwal, Partner with inputs from Anchal Kapoor, Amit Bhalla, and Aakanksha Gupta, Nangia & Co LLP  contributed an article on Secondary adjustments – Analyzing tax, accounting and regulatory implications for Taxsutra.

The Centre is not only eyeing a fair share of taxes on international transactions undertaken between related parties of a multinational network with presence in India, but even untaxed profits stashed overseas. Through fresh measures — popularly called secondary adjustment provisions under transfer pricing — the government has made sure that profits parked abroad via such transactions come back to India within a specified time limit. Amit Agarwal , Partner – Transfer Pricing shares his views for aforementioned story for Hindu Business Line.