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of <h1>Article 10 of DTAA: Tax Adjustments for Profits Between Associated Enterprises in Different States Under Non-Independent Conditions.</h1> Article 10 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if an enterprise in one state participates in the management, control, or capital of an enterprise in the other state, and conditions between them differ from those between independent enterprises, profits that would have accrued to one enterprise but did not due to these conditions may be taxed accordingly. If one state includes such profits in its tax assessments, the other state must adjust its tax charges to reflect what would have been taxed under independent conditions, consulting as necessary.
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