Associated enterprises: profit adjustments allowed where intercompany conditions differ from those between independent enterprises and taxed accordingly. Article 9 treats as associated enterprises where one enterprise participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or the same persons participate in enterprises of both States; if conditions between them differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the profits of the enterprise and taxed accordingly.
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: profit adjustments allowed where intercompany conditions differ from those between independent enterprises and taxed accordingly.
Article 9 treats as associated enterprises where one enterprise participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or the same persons participate in enterprises of both States; if conditions between them differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the profits of the enterprise and taxed accordingly.
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