Associated enterprises rule allows profit adjustment where intercompany conditions differ from independent enterprises' terms. Article 9 provides that where enterprises of the Contracting States are linked by participation in management, control or capital, or by common persons, and conditions between them differ from those between independent enterprises, profits which would have accrued but for those conditions may be included in the profits of the appropriate enterprise and taxed accordingly.
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 rule allows profit adjustment where intercompany conditions differ from independent enterprises' terms.
Article 9 provides that where enterprises of the Contracting States are linked by participation in management, control or capital, or by common persons, and conditions between them differ from those between independent enterprises, profits which would have accrued but for those conditions may be included in the profits of the appropriate enterprise and taxed accordingly.
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