Associated enterprise transfer pricing adjustments require corresponding tax adjustments between contracting states to prevent double taxation. Associated enterprises rules permit inclusion in an enterprise's taxable profits of amounts that would have accrued but for commercial or financial conditions between related enterprises that depart from independent-enterprise conditions. The Corresponding Adjustments mechanism requires the other Contracting State to make an appropriate tax adjustment where one State has included and taxed such profits, with competent authorities consulting as necessary and due regard given to other agreement provisions.
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 enterprise transfer pricing adjustments require corresponding tax adjustments between contracting states to prevent double taxation.
Associated enterprises rules permit inclusion in an enterprise's taxable profits of amounts that would have accrued but for commercial or financial conditions between related enterprises that depart from independent-enterprise conditions. The Corresponding Adjustments mechanism requires the other Contracting State to make an appropriate tax adjustment where one State has included and taxed such profits, with competent authorities consulting as necessary and due regard given to other agreement provisions.
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