Associated enterprises: pricing deviations may be reallocated and taxed, with corresponding adjustments by the other State. Where related enterprises participate in management, control or capital and conditions between them differ from those between independent enterprises, ... Summary
Associated enterprises: pricing deviations may be reallocated and taxed, with corresponding adjustments by the other State.
Where related enterprises participate in management, control or capital and conditions between them differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the taxable profits of the affected enterprise to reflect an arm's length outcome. If one Contracting State taxes such adjusted profits and they have been taxed in the other State, the other State shall make an appropriate tax adjustment, having regard to the Convention and after consultation between the competent authorities if necessary.
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