Associated enterprises: transfer pricing adjustments permit inclusion of reallocated profits in taxable income, with corresponding relief by the other State. Article 9 permits a Contracting State to include in an enterprise's taxable profits amounts that would have accrued but for conditions between linked enterprises that differ from those between independent enterprises. If one State taxes such reallocated profits and the enterprise of the other State is also taxed on them, the latter State shall make an appropriate adjustment to avoid double taxation, taking into account the Convention and after 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 adjustments permit inclusion of reallocated profits in taxable income, with corresponding relief by the other State.
Article 9 permits a Contracting State to include in an enterprise's taxable profits amounts that would have accrued but for conditions between linked enterprises that differ from those between independent enterprises. If one State taxes such reallocated profits and the enterprise of the other State is also taxed on them, the latter State shall make an appropriate adjustment to avoid double taxation, taking into account the Convention and after consultation between the competent authorities.
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