Associated enterprises rule reallocates profits between related enterprises when terms differ from those of independent parties. Associated enterprises provisions address cases where related enterprises in the two Contracting States enter into commercial or financial relations on terms differing from those between independent enterprises; in such cases profits that would have accrued but for those conditions may be included in an enterprise's taxable profits and taxed accordingly to reflect arm's length terms.
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 rule reallocates profits between related enterprises when terms differ from those of independent parties.
Associated enterprises provisions address cases where related enterprises in the two Contracting States enter into commercial or financial relations on terms differing from those between independent enterprises; in such cases profits that would have accrued but for those conditions may be included in an enterprise's taxable profits and taxed accordingly to reflect arm's length terms.
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