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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 9 of DTAA: Tax Adjustments for Profits in Associated Enterprises Across Contracting States</h1> Article 9 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states addresses associated enterprises. It applies when an enterprise in one state participates in the management, control, or capital of an enterprise in the other state, or when the same persons manage enterprises in both states. If conditions between these enterprises differ from those between independent enterprises, profits that should have accrued to one enterprise but did not due to these conditions may be taxed accordingly. If one state adjusts the profits of an enterprise due to such conditions, the other state must make an appropriate tax adjustment, considering the convention's provisions.
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