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of <h1>Article 9: Tax Adjustments for Enterprises with Cross-Border Management, Control, or Capital Under Different Conditions</h1> Article 9 of the Double Tax Avoidance Agreement between two Contracting States addresses associated enterprises. It stipulates that if an enterprise in one state is involved in the management, control, or capital of an enterprise in the other state, and conditions differ from those between independent enterprises, profits that would have accrued but did not due to these conditions may be taxed accordingly. If a state taxes profits that would have accrued under independent conditions, the other state must adjust the tax charged on those profits, considering the Convention's provisions and consulting with competent authorities if necessary.
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