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          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.

          <h1>Associated enterprises rule permits arm's length adjustments to include and reallocate profits between related enterprises.</h1> Where enterprises of the two Contracting States are connected through participation in management, control or capital, or common persons, transactions that differ from those between independent enterprises permit inclusion of profits that would have accrued but for those conditions in taxable income. If one State taxes such profits, the other State shall make an appropriate adjustment to its tax on those profits where it considers the adjustment justified, with regard to the Agreement and consultation between competent authorities.

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