Associated enterprises transfer pricing adjustment enables profit inclusion and mandates corresponding tax relief by the other State. Related enterprises where one participates in the management, control or capital of the other, or where the same persons participate in both, permit a Contracting State to include in an enterprise's profits amounts that would have accrued but for non arm's length conditions and tax those adjusted profits. If those profits have been taxed in the other State, that other State shall make an appropriate corresponding adjustment, 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.
Associated enterprises transfer pricing adjustment enables profit inclusion and mandates corresponding tax relief by the other State.
Related enterprises where one participates in the management, control or capital of the other, or where the same persons participate in both, permit a Contracting State to include in an enterprise's profits amounts that would have accrued but for non arm's length conditions and tax those adjusted profits. If those profits have been taxed in the other State, that other State shall make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between competent authorities.
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