Associated enterprises: non-arm's-length conditions allow inclusion of unrealized profits for taxation. Associated enterprises rules apply where enterprises or the same persons participate in management, control or capital across Contracting States and ... Summary
Associated enterprises: non-arm's-length conditions allow inclusion of unrealized profits for taxation.
Associated enterprises rules apply where enterprises or the same persons participate in management, control or capital across Contracting States and impose conditions in their commercial or financial relations that differ from those between independent enterprises; any profits that would have accrued but for those non-arm's-length conditions may be included in the profits of the enterprise and taxed accordingly.
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