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of <h1>Article 10 of DTAA: Tax Adjustments for Associated Enterprises with Different Conditions than Independent Enterprises Explained.</h1> Article 10 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if an enterprise in one state is involved in the management, control, or capital of an enterprise in the other state, and conditions differ from those between independent enterprises, any profits that should have accrued but did not due to these conditions may be taxed accordingly. If one state taxes profits already taxed in the other state, an appropriate tax adjustment must be made, considering the agreement's provisions, with consultation between competent authorities if necessary.
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