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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 9 of DTAA: Tax Adjustments for Associated Enterprises with Non-Independent Conditions Between Contracting States Explained</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses associated enterprises. It stipulates that if an enterprise in one state is involved in the management, control, or capital of an enterprise in the other state, or if the same persons are involved in both enterprises, and conditions differ from those between independent enterprises, profits that should have accrued but did not due to these conditions can be taxed accordingly. If one state adjusts profits for tax purposes, the other state must make appropriate tax adjustments if justified, with consultation between competent authorities if necessary.
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