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.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
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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