Secondary adjustment requires repatriation or deemed loan treatment when a primary transfer pricing adjustment increases income.

A statutory rule mandates secondary adjustment when a primary transfer pricing adjustment increases income or reduces loss and is effected suo motu, accepted after assessment, determined by an APA, prescribed safe harbour, or mutual agreement procedure. Excess money with an associated enterprise not repatriated within prescribed timeframes is deemed an advance by the taxpayer and attracts interest computed as prescribed; the section defines key terms and provides transitional and monetary-threshold exceptions and an effective date for application.

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