Associated enterprises rule allows transfer pricing adjustments so profits are included and taxed to reflect arm's length dealings. The rule permits adjustments where one enterprise participates in the management, control or capital of an enterprise of the other Contracting State, or the same persons participate in both, and conditions between them 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 accordingly.
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 allows transfer pricing adjustments so profits are included and taxed to reflect arm's length dealings.
The rule permits adjustments where one enterprise participates in the management, control or capital of an enterprise of the other Contracting State, or the same persons participate in both, and conditions between them 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 accordingly.
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