Associated enterprise adjustments permit reallocation of profits when intercompany conditions differ from independent dealings, requiring reciprocal tax adjustments. Article 9 permits inclusion and taxation of profits in an enterprise when intercompany conditions differ from those between independent enterprises, and requires the other Contracting State to make an appropriate corresponding tax adjustment where the same profits are taxed in both States, 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 enterprise adjustments permit reallocation of profits when intercompany conditions differ from independent dealings, requiring reciprocal tax adjustments.
Article 9 permits inclusion and taxation of profits in an enterprise when intercompany conditions differ from those between independent enterprises, and requires the other Contracting State to make an appropriate corresponding tax adjustment where the same profits are taxed in both States, with competent authorities consulting as necessary.
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