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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Article 9 of DTAA: Tax Profits from Non-Arm's Length Conditions in Associated Enterprises to Prevent Tax Avoidance.</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses associated enterprises. It stipulates that when an enterprise from one state participates in the management, control, or capital of an enterprise in the other state, or when the same individuals participate in both enterprises, and non-arm's length conditions are imposed, any profits that would have accrued to one enterprise but did not due to these conditions may be included in that enterprise's taxable profits. This provision ensures that profits are taxed appropriately, preventing tax avoidance through manipulation of inter-company transactions.