Associated enterprises: pricing deviations between related parties may be reallocated and taxed to reflect arm's length conditions. Article 8 permits inclusion in taxable profits and corresponding taxation where enterprises of Contracting States have management, control or capital links and conditions between them differ from those between independent enterprises; profits which would have accrued but for those conditions may be reallocated and taxed, and the procedural mechanisms of each Contracting State's laws shall apply in implementing such adjustments.
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: pricing deviations between related parties may be reallocated and taxed to reflect arm's length conditions.
Article 8 permits inclusion in taxable profits and corresponding taxation where enterprises of Contracting States have management, control or capital links and conditions between them differ from those between independent enterprises; profits which would have accrued but for those conditions may be reallocated and taxed, and the procedural mechanisms of each Contracting State's laws shall apply in implementing such adjustments.
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