Associated enterprises: arm's length reattribution allows tax authorities to correct profit allocation between related cross-border enterprises. Associated enterprises provisions permit reattribution of profits where related parties-through management, control, capital participation, or common ... Summary
Associated enterprises: arm's length reattribution allows tax authorities to correct profit allocation between related cross-border enterprises.
Associated enterprises provisions permit reattribution of profits where related parties-through management, control, capital participation, or common controllers-impose conditions differing from those between independent enterprises; tax authorities may include in taxable profits amounts that would have accrued absent those conditions, applying the arm's length principle to correct profit allocation between Contracting States.
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