Article 9 of DTAA: Adjusting Profits of Associated Enterprises to Prevent Double Taxation Between Contracting States.

Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if enterprises from different Contracting States are related through management, control, or capital, and they establish conditions in their commercial or financial relations that differ from those between independent enterprises, profits that should have accrued to one enterprise but did not due to these conditions may be taxed accordingly. If one state adjusts the profits of an enterprise due to these conditions, the other state must make appropriate tax adjustments, consulting as necessary, to prevent double taxation.