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, ... Summary
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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