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of <h1>Tax Adjustments Get Stricter: New Rules Force Repatriation or Pay 18% Tax on Cross-Border Transactions Between Linked Enterprises</h1> Here's a concise summary of the text:The document analyzes Clause 170 of the Income Tax Bill, 2025, which addresses secondary adjustments in transfer pricing. The provision aims to align economic reality with arm's length pricing by requiring repatriation of excess funds or imposing additional tax when cross-border transactions between associated enterprises deviate from standard pricing. The clause introduces mechanisms to ensure tax adjustments have real economic substance, including options for repatriation or paying an 18% additional tax, closely mirroring the existing Section 92CE of the Income-tax Act, 1961.
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