Secondary adjustment: option to pay additional income tax as final settlement in lieu of repatriation and interest. Amendments expand the scope of secondary adjustment to include primary adjustments under advance pricing agreements entered into on or after the specified date, add a non refund proviso for taxes paid under the prior regime, and clarify that interest is computed on the excess money or part thereof with repatriation permitted from any non resident associated enterprise. A voluntary alternative allows the taxpayer to pay an additional income tax on unrepatriated excess money which shall be treated as the final tax payment, precluding secondary adjustment, further interest computation from the date of payment, deductions for that amount, and claims for credit.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Secondary adjustment: option to pay additional income tax as final settlement in lieu of repatriation and interest.
Amendments expand the scope of secondary adjustment to include primary adjustments under advance pricing agreements entered into on or after the specified date, add a non refund proviso for taxes paid under the prior regime, and clarify that interest is computed on the excess money or part thereof with repatriation permitted from any non resident associated enterprise. A voluntary alternative allows the taxpayer to pay an additional income tax on unrepatriated excess money which shall be treated as the final tax payment, precluding secondary adjustment, further interest computation from the date of payment, deductions for that amount, and claims for credit.
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