Associated enterprises and the arm's length principle require profit adjustments to reflect independent-enterprise conditions and prevent double taxation. Article 9 permits inclusion and taxation of profits where related enterprises transact on terms differing from those between independent enterprises, applying the arm's length principle to adjust profit allocation. It also requires the other Contracting State to make an appropriate corresponding adjustment where adjusted profits have been taxed in both States, with competent authorities consulting as necessary to account for other Agreement provisions.
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 and the arm's length principle require profit adjustments to reflect independent-enterprise conditions and prevent double taxation.
Article 9 permits inclusion and taxation of profits where related enterprises transact on terms differing from those between independent enterprises, applying the arm's length principle to adjust profit allocation. It also requires the other Contracting State to make an appropriate corresponding adjustment where adjusted profits have been taxed in both States, with competent authorities consulting as necessary to account for other Agreement provisions.
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