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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Income Tax Adjustments Mandated for Associated Enterprises Under Article 9 of Double Tax Avoidance Agreement</h1> Article 9 of the Double Tax Avoidance Agreement between Canada and another Contracting State addresses the taxation of income involving associated enterprises. It stipulates that when enterprises in different states are under common control and engage in transactions under conditions differing from those of independent enterprises, any income that should have accrued to one enterprise but did not due to these conditions can be taxed by the relevant state. If a state adjusts the taxable income of an enterprise to reflect independent conditions, the other state must make corresponding tax adjustments. Adjustments are time-limited to five years, except in cases of fraud or neglect.
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