Associated enterprise pricing adjustments allow taxation where intercompany conditions distort profits, permitting corresponding relief in the other jurisdiction. Article 9 permits inclusion in taxable profits where conditions between associated enterprises differ from those between independent enterprises, enabling a State to tax profits shifted by such non-arm's-length conditions. It also allows a corresponding adjustment in the other jurisdiction when the same profits have been taxed there, with consultation between competent authorities and regard to the Agreement's provisions to determine an appropriate tax modification.
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Associated enterprise pricing adjustments allow taxation where intercompany conditions distort profits, permitting corresponding relief in the other jurisdiction.
Article 9 permits inclusion in taxable profits where conditions between associated enterprises differ from those between independent enterprises, enabling a State to tax profits shifted by such non-arm's-length conditions. It also allows a corresponding adjustment in the other jurisdiction when the same profits have been taxed there, with consultation between competent authorities and regard to the Agreement's provisions to determine an appropriate tax modification.
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