Associated enterprises adjustments allow inclusion of unaccrued profits for taxation when conditions deviate from arm's length. Article 9 permits transfer pricing adjustments where enterprises of the Contracting States are associated through management, control or capital, or common persons, and where commercial or financial conditions between them differ from those between independent enterprises, by allowing inclusion in the profits of an enterprise of amounts that would have accrued but for those non arm's length conditions and taxing them accordingly.
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 adjustments allow inclusion of unaccrued profits for taxation when conditions deviate from arm's length.
Article 9 permits transfer pricing adjustments where enterprises of the Contracting States are associated through management, control or capital, or common persons, and where commercial or financial conditions between them differ from those between independent enterprises, by allowing inclusion in the profits of an enterprise of amounts that would have accrued but for those non arm's length conditions and taxing them accordingly.
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