Associated enterprises transfer pricing: profits may be reallocated where conditions differ, with corresponding tax adjustment by the other State. Article 9 permits tax authorities to include in taxable profits amounts that would have accrued but for related-party conditions differing from those between independent enterprises; where one State taxes such adjusted profits already taxed in the other State, the other State shall make an appropriate corresponding adjustment if it agrees the amounts reflect arm's-length profits, with competent authorities consulting as necessary.
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: profits may be reallocated where conditions differ, with corresponding tax adjustment by the other State.
Article 9 permits tax authorities to include in taxable profits amounts that would have accrued but for related-party conditions differing from those between independent enterprises; where one State taxes such adjusted profits already taxed in the other State, the other State shall make an appropriate corresponding adjustment if it agrees the amounts reflect arm's-length profits, with competent authorities consulting as necessary.
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