Associated enterprises transfer pricing adjustments permit reallocation of profits to reflect arm's length commercial and financial conditions. Where an enterprise of one Contracting State participates in the management, control or capital of an enterprise of the other State, or the same persons participate in both, they are associated enterprises; if their commercial or financial conditions differ from those between independent enterprises so that profits which would have accrued do not, those profits may be included in the taxable profits of the enterprise and taxed accordingly, enabling adjustment to reflect arm's-length outcomes.
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.
Associated enterprises transfer pricing adjustments permit reallocation of profits to reflect arm's length commercial and financial conditions.
Where an enterprise of one Contracting State participates in the management, control or capital of an enterprise of the other State, or the same persons participate in both, they are associated enterprises; if their commercial or financial conditions differ from those between independent enterprises so that profits which would have accrued do not, those profits may be included in the taxable profits of the enterprise and taxed accordingly, enabling adjustment to reflect arm's-length outcomes.
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