Associated enterprise rules allow profit inclusion and corresponding tax adjustment when intercompany conditions deviate from arm's length terms. Associated enterprise rules permit inclusion in taxable profits where enterprises of the Contracting States are linked by participation in management, control or capital or by common persons and where conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be included and taxed. Where one State includes and taxes such profits, the other State shall make an appropriate corresponding adjustment to its tax, with competent authorities giving due regard to the Agreement and consulting if necessary.
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 enterprise rules allow profit inclusion and corresponding tax adjustment when intercompany conditions deviate from arm's length terms.
Associated enterprise rules permit inclusion in taxable profits where enterprises of the Contracting States are linked by participation in management, control or capital or by common persons and where conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be included and taxed. Where one State includes and taxes such profits, the other State shall make an appropriate corresponding adjustment to its tax, with competent authorities giving due regard to the Agreement and consulting if necessary.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
