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of <h1>Article 9 of DTAA: Tax Adjustments for Associated Enterprises with Non-Independent Conditions Between Contracting States</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses associated enterprises. It stipulates that when an enterprise from one state participates in the management, control, or capital of an enterprise in the other state, and conditions imposed differ from those between independent enterprises, profits that should have accrued but did not due to these conditions may be taxed. If one state taxes profits that should have accrued to an enterprise in the other state under independent conditions, the latter state must adjust the tax accordingly, considering the agreement's provisions and consulting competent authorities if necessary.
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