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of <h1>Article 9 of DTAA: Profits Adjustments for Associated Enterprises to Prevent Double Taxation</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if enterprises in different Contracting States are under common management, control, or capital, and their financial relations differ from those of independent enterprises, profits that would have accrued to one enterprise but did not due to these conditions may be taxed accordingly. If one State taxes profits that would have accrued under independent conditions, the other State must adjust its tax to avoid double taxation, consulting with the other State if necessary.
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