Associated enterprises rule allows transfer pricing adjustments where connected parties set non arm's length commercial or financial conditions. Where enterprises in the two Contracting States are connected by participation in management, control or capital, or share common persons controlling ... Summary
Associated enterprises rule allows transfer pricing adjustments where connected parties set non arm's length commercial or financial conditions.
Where enterprises in the two Contracting States are connected by participation in management, control or capital, or share common persons controlling them, and commercial or financial conditions between them differ from those between independent enterprises, profits that would have accrued but for those non arm's length conditions may be included in the profits of the enterprise and taxed accordingly.
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