Associated enterprise rules adjust taxable profits where controlled conditions deviate from arm's length dealings, requiring tax adjustments. Article 9 allows a Contracting State to include in the taxable profits of an enterprise amounts that would have accrued but for controlled conditions between associated enterprises, applying arm's length comparisons. If such profits are taxed in both States, the other State must make an appropriate adjustment, with due regard to the Convention and consultation between the competent authorities if necessary.
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 enterprise rules adjust taxable profits where controlled conditions deviate from arm's length dealings, requiring tax adjustments.
Article 9 allows a Contracting State to include in the taxable profits of an enterprise amounts that would have accrued but for controlled conditions between associated enterprises, applying arm's length comparisons. If such profits are taxed in both States, the other State must make an appropriate adjustment, with due regard to the Convention and consultation between the competent authorities if necessary.
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