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of <h1>Article 9 of DTAA: Adjustments to Taxation of Associated Enterprises for Non-Independent Relations, Excluding Fraud or Negligence Cases.</h1> Article 9 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if enterprises in different Contracting States have interdependent management, control, or capital, and their commercial or financial relations deviate from those between independent enterprises, profits that should have accrued but did not due to these conditions can be taxed accordingly. If one State taxes profits that would have accrued under independent conditions, the other State must adjust the tax charged. However, this adjustment does not apply if legal proceedings determine fraud, gross negligence, or willful default by the enterprises.
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