Transfer pricing adjustments: reallocate profits when conditions between associated enterprises differ and corresponding tax adjustment required. Article 9 permits inclusion in an enterprise's taxable profits of amounts that would have accrued but for conditions between associated enterprises that deviate from those between independent enterprises, enabling transfer pricing adjustments to reallocate profits. When one Contracting State taxes profits after such an inclusion, the other Contracting State shall make an appropriate corresponding adjustment to the tax charged on those profits, with due regard to the Convention and consultation between the competent authorities if necessary.
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.
Transfer pricing adjustments: reallocate profits when conditions between associated enterprises differ and corresponding tax adjustment required.
Article 9 permits inclusion in an enterprise's taxable profits of amounts that would have accrued but for conditions between associated enterprises that deviate from those between independent enterprises, enabling transfer pricing adjustments to reallocate profits. When one Contracting State taxes profits after such an inclusion, the other Contracting State shall make an appropriate corresponding adjustment to the tax charged on those profits, with due regard to the Convention and consultation between the competent authorities if necessary.
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