Associated enterprises rules permit profit adjustments for non arm's length conditions and require corresponding tax adjustments. Article 10 permits inclusion in taxable profits where conditions between related enterprises differ from those which would have been made between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one Contracting State taxes such adjusted profits that have been charged to tax in the other State, that other State shall make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between the 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 enterprises rules permit profit adjustments for non arm's length conditions and require corresponding tax adjustments.
Article 10 permits inclusion in taxable profits where conditions between related enterprises differ from those which would have been made between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one Contracting State taxes such adjusted profits that have been charged to tax in the other State, that other State shall make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between the competent authorities if necessary.
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