Associated enterprises transfer pricing adjustments require corresponding tax adjustments and consultations between Contracting States to prevent double taxation Article 9 permits inclusion in taxable income where associated enterprises transact on conditions differing from those between independent enterprises, allowing the affected enterprise's income to be adjusted and taxed. If one State taxes such income, the other State must provide an appropriate corresponding adjustment after consulting competent authorities and considering the Agreement. Adjustments are subject to national limitation periods and a general five year time limit, but that limit does not apply in cases of fraud, wilful default or neglect.
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Associated enterprises transfer pricing adjustments require corresponding tax adjustments and consultations between Contracting States to prevent double taxation
Article 9 permits inclusion in taxable income where associated enterprises transact on conditions differing from those between independent enterprises, allowing the affected enterprise's income to be adjusted and taxed. If one State taxes such income, the other State must provide an appropriate corresponding adjustment after consulting competent authorities and considering the Agreement. Adjustments are subject to national limitation periods and a general five year time limit, but that limit does not apply in cases of fraud, wilful default or neglect.
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