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 ... Summary
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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