Union Budget 2019 – Transfer Pricing Proposals
India Budget 2019 includes a number of proposals on transfer
pricing that shall have a material impact on cross-border
transactions. In this article, we present an overview of the
transfer pricing proposals under Union Budget 2019 and how the same
shall impact multinational companies insofar as their Transfer
Pricing Compliance is concerned.
I. Clarification on Secondary Adjustment
What is Secondary Adjustment?
A secondary adjustment is an adjustment over and above the
primary adjustment in the taxpayer's books of accounts to
reflect actual allocation of profits between the Associated
Enterprises ('AEs') to be consistent with the transfer
prices determined under a Transfer Pricing Adjustment (i.e. the
Primary Adjustment).
