Associated enterprises transfer pricing adjustments require corresponding tax adjustments and competent authority consultation. Where related enterprises set conditions between them that differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the profits of the enterprise to which they would have accrued and taxed accordingly. When one Contracting State includes and taxes such profits, the other Contracting State shall make an appropriate adjustment to the tax charged on those profits, with due regard to the agreement and consultation between competent authorities; the Multilateral Instrument corresponding adjustment rule supersedes the bilateral provision.
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 require corresponding tax adjustments and competent authority consultation.
Where related enterprises set conditions between them that differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the profits of the enterprise to which they would have accrued and taxed accordingly. When one Contracting State includes and taxes such profits, the other Contracting State shall make an appropriate adjustment to the tax charged on those profits, with due regard to the agreement and consultation between competent authorities; the Multilateral Instrument corresponding adjustment rule supersedes the bilateral provision.
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