Associated enterprises adjustments ensure arm's length profits are taxed and permit corresponding relief to prevent double taxation. Where related enterprises enter into non-arm's-length conditions, profits that would have accrued under arm's-length conditions may be included in an enterprise's taxable profits and taxed. If both Contracting States tax the same profits, the other State shall make an appropriate corresponding adjustment, with due regard to the Convention and consultation between competent authorities.
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Provisions expressly mentioned in the judgment/order text.
Associated enterprises adjustments ensure arm's length profits are taxed and permit corresponding relief to prevent double taxation.
Where related enterprises enter into non-arm's-length conditions, profits that would have accrued under arm's-length conditions may be included in an enterprise's taxable profits and taxed. If both Contracting States tax the same profits, the other State shall make an appropriate corresponding adjustment, with due regard to the Convention and consultation between competent authorities.
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