Associated enterprises rule permits profit adjustments where related-party conditions deviate from arm's length, triggering tax adjustments. Associated enterprises provisions allow a Contracting State to include in taxable profits amounts that would have accrued but for non-arm's-length conditions between related enterprises, and require the other State to make an appropriate adjustment where those profits have been taxed there, with due regard to the Convention and consultation between competent authorities.
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 rule permits profit adjustments where related-party conditions deviate from arm's length, triggering tax adjustments.
Associated enterprises provisions allow a Contracting State to include in taxable profits amounts that would have accrued but for non-arm's-length conditions between related enterprises, and require the other State to make an appropriate adjustment where those profits have been taxed there, with due regard to the Convention and consultation between competent authorities.
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