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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 9: Reallocate profits between related enterprises when conditions differ, and adjust to prevent double taxation</h1> Where enterprises of two Contracting States are related by participation in management, control or capital, or by common persons controlling both, and their commercial or financial relations contain conditions different from those between independent enterprises, profits that would have accrued but for those conditions may be reallocated and taxed accordingly by the State where the enterprise is resident. If one State taxes such reallocated profits which were already taxed in the other State, that other State must make an appropriate adjustment to avoid double taxation, taking account of the treaty and consulting competent authorities as necessary.
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