Associated enterprises arm's length adjustments can reallocate profits and require corresponding treaty tax adjustments by the other State. Article 9 permits inclusion in taxable profits where associated enterprises impose conditions differing from those between independent enterprises; profits that would have accrued absent those conditions may be taxed. If one Contracting State taxes such adjusted profits also charged in the other State, the latter shall make an appropriate tax adjustment, 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.
Associated enterprises arm's length adjustments can reallocate profits and require corresponding treaty tax adjustments by the other State.
Article 9 permits inclusion in taxable profits where associated enterprises impose conditions differing from those between independent enterprises; profits that would have accrued absent those conditions may be taxed. If one Contracting State taxes such adjusted profits also charged in the other State, the latter shall make an appropriate tax adjustment, with due regard to the Convention and consultation between competent authorities.
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