Corresponding adjustments reservation limits application of the treaty provision where existing bilateral agreements already provide equivalent transfer pricing adjustments. India reserves the right that the Convention's corresponding adjustments rule will not apply to its Covered Tax Agreements that already contain a provision equivalent to the Convention's corresponding adjustments mechanism, and lists the bilateral treaties whose existing provisions are within the scope of that reservation, thereby excluding those agreements from application of the Convention's corresponding adjustments rule.
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 reservation limits application of the treaty provision where existing bilateral agreements already provide equivalent transfer pricing adjustments.
India reserves the right that the Convention's corresponding adjustments rule will not apply to its Covered Tax Agreements that already contain a provision equivalent to the Convention's corresponding adjustments mechanism, and lists the bilateral treaties whose existing provisions are within the scope of that reservation, thereby excluding those agreements from application of the Convention's corresponding adjustments rule.
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