Associated enterprises principle permits profit adjustments where intercompany conditions differ from those between independent enterprises. Article 9 defines associated enterprises by direct or indirect participation in management, control or capital, or by common persons participating in ... Summary
Associated enterprises principle permits profit adjustments where intercompany conditions differ from those between independent enterprises.
Article 9 defines associated enterprises by direct or indirect participation in management, control or capital, or by common persons participating in enterprises of both Contracting States. If conditions in commercial or financial relations between such enterprises differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the enterprise's profits and taxed accordingly, permitting adjustments to reflect independent-enterprise conditions.
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