Associated enterprises principle permits adjustment of profits between related parties to reflect arm's length conditions and corresponding tax relief. Associated enterprises rules permit inclusion in taxable profits of amounts that would have accrued under arm's length conditions where cross border related party management, control or capital participation leads to conditions differing from independent enterprises. If such adjusted profits are taxed in one Contracting State and also charged to tax in the other, the other State shall make an appropriate adjustment, with competent authorities consulting and having regard to the Agreement's other provisions.
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 principle permits adjustment of profits between related parties to reflect arm's length conditions and corresponding tax relief.
Associated enterprises rules permit inclusion in taxable profits of amounts that would have accrued under arm's length conditions where cross border related party management, control or capital participation leads to conditions differing from independent enterprises. If such adjusted profits are taxed in one Contracting State and also charged to tax in the other, the other State shall make an appropriate adjustment, with competent authorities consulting and having regard to the Agreement's other provisions.
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