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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 9 of DTAA: Tax Rules for Associated Enterprises in Brazil and Partner State Clarified on Profit Allocation.</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between Brazil and another Contracting State addresses associated enterprises. It stipulates that if an enterprise of one state participates in the management, control, or capital of an enterprise in the other state, or if the same individuals participate in both enterprises, and if conditions in their commercial or financial relations differ from those between independent enterprises, any profits that would have accrued to one enterprise but did not due to these conditions may be included in the profits of that enterprise and taxed accordingly.
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