Corresponding adjustments for transfer pricing: other jurisdictions must make tax adjustments and consult competent authorities. Where one Contracting Jurisdiction taxes profits attributable to conditions between associated enterprises that differ from those between independent enterprises, the other Contracting Jurisdiction shall make an appropriate adjustment to its tax on those profits. Competent authorities must consider the Covered Tax Agreement and consult if necessary. The rule replaces or supplements existing bilateral corresponding-adjustment provisions, subject to Parties' reservations and notifications, and preserves the mutual agreement procedure as an alternative resolution route.
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.
Corresponding adjustments for transfer pricing: other jurisdictions must make tax adjustments and consult competent authorities.
Where one Contracting Jurisdiction taxes profits attributable to conditions between associated enterprises that differ from those between independent enterprises, the other Contracting Jurisdiction shall make an appropriate adjustment to its tax on those profits. Competent authorities must consider the Covered Tax Agreement and consult if necessary. The rule replaces or supplements existing bilateral corresponding-adjustment provisions, subject to Parties' reservations and notifications, and preserves the mutual agreement procedure as an alternative resolution route.
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