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 ... Summary
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.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.