Associated enterprises principle permits adjustment of profits where conditions deviate from arm's length and taxed accordingly. Article 10 applies where enterprises are associated by direct or indirect participation in management, control or capital, or by common participation, and ... Summary
Associated enterprises principle permits adjustment of profits where conditions deviate from arm's length and taxed accordingly.
Article 10 applies where enterprises are associated by direct or indirect participation in management, control or capital, or by common participation, and where commercial or financial conditions between them differ from those between independent enterprises; in such cases profits that would have accrued but for those conditions may be included in the profits of an enterprise and taxed accordingly to restore an arm's length allocation.
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