Associated enterprises adjustments: cross-border transfer pricing corrections require corresponding tax adjustments and mutual consultation protocols. Where enterprises across Contracting States have interposed conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits; when one State taxes such adjusted profits that have also been taxed in the other State, that other State must make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between 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 adjustments: cross-border transfer pricing corrections require corresponding tax adjustments and mutual consultation protocols.
Where enterprises across Contracting States have interposed conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits; when one State taxes such adjusted profits that have also been taxed in the other State, that other State must make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between competent authorities.
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