Associated enterprises: transfer pricing adjustments permit reallocation of profits and taxation, with double taxation addressed by mutual agreement. Article 9 treats enterprises as associated where direct or indirect participation in management, control or capital exists or the same persons participate in enterprises of both Contracting States. If conditions between associated enterprises differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits and taxed. Double taxation arising from such adjustments may be resolved by the mutual agreement procedure.
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 adjustments permit reallocation of profits and taxation, with double taxation addressed by mutual agreement.
Article 9 treats enterprises as associated where direct or indirect participation in management, control or capital exists or the same persons participate in enterprises of both Contracting States. If conditions between associated enterprises differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits and taxed. Double taxation arising from such adjustments may be resolved by the mutual agreement procedure.
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