Arm's length principle applied to associated enterprises: profit reallocation and corresponding tax adjustment between jurisdictions. Article 9 applies the arm's length principle to associated enterprises where management, control or capital participation leads to conditions differing from those between independent enterprises; it allows adjustment of taxable profits to reflect amounts that would have accrued under arm's-length conditions and requires the other Contracting State to make corresponding tax adjustments with due regard to the Convention and consultation between competent authorities.
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.
Arm's length principle applied to associated enterprises: profit reallocation and corresponding tax adjustment between jurisdictions.
Article 9 applies the arm's length principle to associated enterprises where management, control or capital participation leads to conditions differing from those between independent enterprises; it allows adjustment of taxable profits to reflect amounts that would have accrued under arm's-length conditions and requires the other Contracting State to make corresponding tax adjustments with due regard to the Convention and consultation between competent authorities.
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