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of <h1>Article 9 of DTAA: Tax Adjustments for Associated Enterprises with Interconnected Management or Control Across States</h1> Article 9 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of income involving associated enterprises. When enterprises in different states have interconnected management, control, or capital, and conditions differ from those between independent entities, income that should have accrued to one enterprise but did not due to these conditions may be taxed. If one state taxes income that would have accrued under independent conditions, the other state must adjust its tax accordingly. Adjustments must respect treaty provisions, and changes in income cannot occur after five years, except in cases of fraud or neglect.
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