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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Enterprises Must Transact at Arm's Length: Transfer Pricing Rules Prevent Artificial Profit Shifting Under DTAA Article 9</h1> The Article 9 of a Double Tax Avoidance Agreement (DTAA) addressing associated enterprises. It establishes rules for taxation when related enterprises have commercial or financial relationships that differ from independent market conditions. If conditions artificially manipulate profits, tax authorities can reallocate profits to reflect arm's length transactions, ensuring fair taxation across jurisdictions and preventing tax avoidance through transfer pricing manipulation.