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of <h1>Article 9 of DTAA: Addressing Taxation of Associated Enterprises and Adjustments to Prevent Double Taxation</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of associated enterprises. It stipulates that if enterprises in different states engage in transactions under conditions differing from those between independent enterprises, profits that would have accrued but did not due to such conditions may be taxed. If one state adjusts the taxable profits of an enterprise due to such conditions, the other state must make corresponding adjustments to prevent double taxation, unless fraud, gross negligence, or willful default is involved, as determined by legal proceedings.
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