Associated enterprises: arm's length reattribution allows tax authorities to correct profit allocation between related cross-border enterprises. Associated enterprises provisions permit reattribution of profits where related parties-through management, control, capital participation, or common controllers-impose conditions differing from those between independent enterprises; tax authorities may include in taxable profits amounts that would have accrued absent those conditions, applying the arm's length principle to correct profit allocation between Contracting States.
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: arm's length reattribution allows tax authorities to correct profit allocation between related cross-border enterprises.
Associated enterprises provisions permit reattribution of profits where related parties-through management, control, capital participation, or common controllers-impose conditions differing from those between independent enterprises; tax authorities may include in taxable profits amounts that would have accrued absent those conditions, applying the arm's length principle to correct profit allocation between Contracting States.
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