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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 9 of Double Tax Avoidance Agreement: Tax Adjustments for Associated Enterprises with Management Control Across States.</h1> Article 9 of the Double Tax Avoidance Agreement between Korea and another Contracting State addresses associated enterprises. It stipulates that if an enterprise in one state participates in the management or control of an enterprise in the other state, and conditions differ from those between independent enterprises, any profits not accrued due to such conditions may be taxed. If profits are taxed in one state but would have accrued to the other state under independent conditions, the latter state must adjust the tax appropriately, considering the agreement's provisions and consulting with the other state's authorities if needed.
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