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of <h1>Article 9 of DTAA Allows Tax Adjustments for Associated Enterprises Under Common Control with Non-Independent Conditions.</h1> Article 9 of the Double Taxation Avoidance Agreement (DTAA) between Indonesia and another Contracting State addresses associated enterprises. It stipulates that if enterprises in different Contracting States are under common control and engage in transactions under conditions differing from those between independent enterprises, profits that should have accrued to one enterprise but did not due to such conditions can be adjusted and taxed accordingly. Additionally, if profits taxed in one state would have accrued to an enterprise in the other state under independent conditions, the latter state must make an appropriate tax adjustment, considering the agreement's provisions and consulting the competent authorities if needed.
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