Associated enterprises transfer pricing: reallocation of profits permitted and counterpart state must provide corresponding tax adjustment. Associated enterprises rules allow reallocation of profits where control or common participation produces conditions differing from those between independent enterprises; such reallocated profits may be included in and taxed in the enterprise's taxable base. Article 17 of the MLI requires the other Contracting State to make an appropriate corresponding adjustment to its tax when the first State taxes profits that would have accrued to the other enterprise, with regard to the Agreement's provisions and after competent-authority consultation if necessary.
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: reallocation of profits permitted and counterpart state must provide corresponding tax adjustment.
Associated enterprises rules allow reallocation of profits where control or common participation produces conditions differing from those between independent enterprises; such reallocated profits may be included in and taxed in the enterprise's taxable base. Article 17 of the MLI requires the other Contracting State to make an appropriate corresponding adjustment to its tax when the first State taxes profits that would have accrued to the other enterprise, with regard to the Agreement's provisions and after competent-authority consultation if necessary.
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