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of <h1>Adjusting Profits Under DTAA Article 9: Managing Interdependent Enterprises and Taxation with MLI Article 17 Provisions</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between Belgium and another Contracting State addresses associated enterprises. It stipulates that if enterprises in the two states have interdependent management, control, or capital, and set commercial or financial conditions differing from those between independent enterprises, profits that would have accrued but did not due to these conditions may be adjusted and taxed. Article 17 of the Multilateral Instrument (MLI) allows for corresponding adjustments, requiring the other state to adjust tax charges to reflect profits as if independent conditions existed, with consultation between competent authorities if necessary.
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