Associated enterprises adjustment: transfer pricing deviations permit inclusion of attributable profits and require reciprocal tax adjustments. Article 10 applies the arm's length principle to Associated Enterprises: where related enterprises enter into conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in the taxable profits of the enterprise that benefited and taxed. If one State taxes such included profits which were taxed in the other State, that other State shall make an appropriate tax adjustment, with competent authorities consulting as necessary to determine the adjustment.
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 adjustment: transfer pricing deviations permit inclusion of attributable profits and require reciprocal tax adjustments.
Article 10 applies the arm's length principle to Associated Enterprises: where related enterprises enter into conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in the taxable profits of the enterprise that benefited and taxed. If one State taxes such included profits which were taxed in the other State, that other State shall make an appropriate tax adjustment, with competent authorities consulting as necessary to determine the adjustment.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
