Associated enterprises: transfer pricing adjustment permits inclusion of profits omitted due to non arm's length related party conditions. Where enterprises in different Contracting States are linked by direct or indirect participation in management, control or capital, and related party conditions 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; the rule functions as an arm's length transfer pricing adjustment for associated enterprises.
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 adjustment permits inclusion of profits omitted due to non arm's length related party conditions.
Where enterprises in different Contracting States are linked by direct or indirect participation in management, control or capital, and related party conditions 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; the rule functions as an arm's length transfer pricing adjustment for associated enterprises.
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