Associated enterprise adjustments enforce arm's length profit allocation and require reciprocal tax adjustments between Contracting States. Associated enterprises rules permit a Contracting State to include in the taxable profits of an enterprise amounts that would have accrued but for non-arm's-length conditions imposed between related enterprises, and require the other State to make an appropriate adjustment to its tax where both States tax the corresponding profits, 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 enforce arm's length profit allocation and require reciprocal tax adjustments between Contracting States.
Associated enterprises rules permit a Contracting State to include in the taxable profits of an enterprise amounts that would have accrued but for non-arm's-length conditions imposed between related enterprises, and require the other State to make an appropriate adjustment to its tax where both States tax the corresponding profits, with competent authorities consulting as necessary.
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