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of <h1>Article 9 of DTAA Ensures Fair Taxation for Associated Enterprises, Prevents Double Taxation with Profit Adjustments</h1> Article 9 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of associated enterprises. It stipulates that if enterprises in different states are under common management, control, or capital, and engage in transactions that deviate from those between independent enterprises, profits that should have accrued but did not due to these conditions can be taxed accordingly. If one state adjusts the taxable profits of an enterprise due to such conditions, the other state must make appropriate tax adjustments to avoid double taxation, with consultations between competent authorities if necessary.
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