Associated enterprise rules require transfer pricing adjustments and matching tax adjustments across contracting states. Associated enterprise rules allow adjustment of profits when enterprises of the two Contracting States are linked by management, control or capital or by common participation and their commercial or financial conditions differ from those between independent enterprises; profits displaced by non-arm's-length conditions may be included in taxable income. When one State includes such profits and taxes them, the other State shall make an appropriate corresponding tax adjustment, with due regard to the Convention and following consultation between competent authorities 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 enterprise rules require transfer pricing adjustments and matching tax adjustments across contracting states.
Associated enterprise rules allow adjustment of profits when enterprises of the two Contracting States are linked by management, control or capital or by common participation and their commercial or financial conditions differ from those between independent enterprises; profits displaced by non-arm's-length conditions may be included in taxable income. When one State includes such profits and taxes them, the other State shall make an appropriate corresponding tax adjustment, with due regard to the Convention and following consultation between competent authorities if necessary.
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