Transfer pricing adjustments: associated enterprises may have profits reallocated and corresponding tax adjustments required. Article 9 applies an arm's-length standard to transactions between associated enterprises: where control or common participation results in conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable income and taxed. If one Contracting State taxes such adjusted profits, the other State must make an appropriate adjustment to avoid double taxation, with due regard to the Agreement and consultation between competent authorities.
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.
Transfer pricing adjustments: associated enterprises may have profits reallocated and corresponding tax adjustments required.
Article 9 applies an arm's-length standard to transactions between associated enterprises: where control or common participation results in conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable income and taxed. If one Contracting State taxes such adjusted profits, the other State must make an appropriate adjustment to avoid double taxation, with due regard to the Agreement and consultation between competent authorities.
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