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of <h1>Adjustments Under Article 9 of DTAA: Ensuring Fair Taxation for Associated Enterprises with Article 17 of MLI Provisions</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if an enterprise from one state is involved in the management, control, or capital of an enterprise in the other state, and conditions differ from those between independent enterprises, profits that should have accrued may be adjusted and taxed accordingly. Article 17 of the Multilateral Instrument (MLI) allows for corresponding adjustments, ensuring that if one state taxes profits that should have accrued to the other, the latter state will adjust the tax amount to avoid double taxation, with consultation between competent authorities if necessary.
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