Related party transfer pricing adjustments permit inclusion of arm's length profits and cross border tax adjustments follow to prevent mismatches. Where enterprises of the Contracting States are related and commercial or financial conditions between them differ from those between independent ... Summary
Related party transfer pricing adjustments permit inclusion of arm's length profits and cross border tax adjustments follow to prevent mismatches.
Where enterprises of the Contracting States are related and commercial or financial conditions between them differ from those between independent enterprises, amounts that would have accrued but for those conditions may be included in and taxed as the profits of the enterprise. If one State taxes such adjusted profits which are also taxed in the other State, the other State shall make an appropriate adjustment; competent authorities shall consult each other and have regard to the Convention's provisions in determining that adjustment.
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