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of <h1>Article 9 of DTAA: Adjustments in Taxation for Associated Enterprises Under Common Control to Ensure Fair Profit Allocation.</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of associated enterprises. It stipulates that if enterprises in different Contracting States are under common management, control, or capital, 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 these conditions can be included in its taxable profits. If one State adjusts the profits of an enterprise due to such conditions, the other State must make corresponding tax adjustments, consulting as necessary to ensure compliance with the Convention.
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