Associated enterprise pricing adjustments permit reallocation of profits and taxation where intercompany conditions differ from independent dealings. Article 9 permits adjustment of profits where enterprises are associated through direct or indirect participation in management, control or capital, or by common persons; if commercial or financial conditions between them differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the enterprise's taxable profits and taxed accordingly.
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 pricing adjustments permit reallocation of profits and taxation where intercompany conditions differ from independent dealings.
Article 9 permits adjustment of profits where enterprises are associated through direct or indirect participation in management, control or capital, or by common persons; if commercial or financial conditions between them differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the enterprise's taxable profits and taxed accordingly.
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