Associated enterprises: transfer pricing adjustments permit reallocation of profits and mandate corresponding tax adjustments. Associated enterprises rules permit reallocation of profits where conditions between related enterprises differ from arm's-length conditions, allowing profits that would have accrued but for those conditions to be included in and taxed on the affected enterprise; where such reallocated profits are taxed in both Contracting States, the first State to tax shall make an appropriate adjustment, having regard to other Convention provisions on the nature of the income.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Associated enterprises: transfer pricing adjustments permit reallocation of profits and mandate corresponding tax adjustments.
Associated enterprises rules permit reallocation of profits where conditions between related enterprises differ from arm's-length conditions, allowing profits that would have accrued but for those conditions to be included in and taxed on the affected enterprise; where such reallocated profits are taxed in both Contracting States, the first State to tax shall make an appropriate adjustment, having regard to other Convention provisions on the nature of the income.
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