'Vivad se Vishwas': MNCs will have to bring all disputed amount to India

Else, the entire money will be considered as loan from subsidiaries on which interest will have to be paid

The subsidiaries of multinational companies (MNCs) can settle their transfer pricing disputes under the proposed Vivad se Vishwas scheme, but they will have to bring the entire disputed money to India.

Or else, the money not brought into India will be considered as loan from subsidiaries on which interest has to be paid.

According to the amendments to the Direct Tax Vivad se Vishwas Bill, the settling of disputes regarding transfer pricing adjustment would not have any effect on secondary adjustment. Secondary adjustment is repatriation of an excess amount MNCs keep after tax officers make adjustments.  

If an Indian subsidiary