Associated enterprises transfer pricing: non-arm's-length conditions permit profit inclusion and reciprocal tax adjustment. Where enterprises of the Contracting States are connected by participation in management, control or capital, or by common persons, and conditions between ... Summary
Associated enterprises transfer pricing: non-arm's-length conditions permit profit inclusion and reciprocal tax adjustment.
Where enterprises of the Contracting States are connected by participation in management, control or capital, or by common persons, and conditions between them differ from those that would be made between independent enterprises, profits that would have accrued but for those conditions may be included in and taxed as the enterprise's profits. If one State taxes such reallocated profits that have been charged to tax in the other State, the other State shall make an appropriate adjustment to its tax, with due regard to the Agreement's provisions and consultation between competent authorities.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 1 
Join Channel 
