Associated enterprises transfer pricing: corresponding tax adjustments required when intercompany conditions differ from independent dealings. Article 10 defines associated enterprises by participation in management, control or capital and permits inclusion in taxable profits where intercompany conditions differ from those between independent enterprises; it also provides for a corresponding adjustment by the other Contracting State when both States tax the same profits, subject to consultation between competent authorities and regard to the Convention's other provisions.
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 transfer pricing: corresponding tax adjustments required when intercompany conditions differ from independent dealings.
Article 10 defines associated enterprises by participation in management, control or capital and permits inclusion in taxable profits where intercompany conditions differ from those between independent enterprises; it also provides for a corresponding adjustment by the other Contracting State when both States tax the same profits, subject to consultation between competent authorities and regard to the Convention's other provisions.
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