Associated enterprises adjustments permit reallocation of profits to reflect arm's length conditions and relieve double taxation. Article 9 permits inclusion in taxable profits of amounts that would have accrued but for non-arm's-length conditions between enterprises with direct or ... Summary
Associated enterprises adjustments permit reallocation of profits to reflect arm's length conditions and relieve double taxation.
Article 9 permits inclusion in taxable profits of amounts that would have accrued but for non-arm's-length conditions between enterprises with direct or indirect participation in management, control or capital, and requires the other Contracting State to make an appropriate adjustment where those profits have been taxed there, with competent authorities consulting as necessary.
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