Associated enterprises transfer pricing: permits profit reallocation where intercompany conditions differ and requires corresponding tax adjustment. Article 9 permits inclusion in taxable profits where enterprises are associated and commercial or financial conditions between them differ from those between independent enterprises, allowing profits that would have accrued but for those conditions to be taxed. It requires the other Contracting State to make an appropriate corresponding adjustment if it has already taxed those profits, with due regard to the Agreement and consultation between the competent authorities.
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 transfer pricing: permits profit reallocation where intercompany conditions differ and requires corresponding tax adjustment.
Article 9 permits inclusion in taxable profits where enterprises are associated and commercial or financial conditions between them differ from those between independent enterprises, allowing profits that would have accrued but for those conditions to be taxed. It requires the other Contracting State to make an appropriate corresponding adjustment if it has already taxed those profits, with due regard to the Agreement and consultation between the competent authorities.
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