Arm's length principle: permit tax adjustments where associated enterprises' conditions shift profits between related enterprises. Article 9 provides that where enterprises of the two Contracting States are associated through participation in management, control or capital, or common ... Summary
Arm's length principle: permit tax adjustments where associated enterprises' conditions shift profits between related enterprises.
Article 9 provides that where enterprises of the two Contracting States are associated through participation in management, control or capital, or common persons participate in both, and conditions between them differ from those between independent enterprises, any profits which would have accrued but for those conditions may be included in the profits of the relevant enterprise and taxed accordingly as a transfer-pricing adjustment to reflect arm's-length results.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.