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of <h1>OECD Model Tax Convention Article 9: Taxation of Associated Enterprises and Profit Adjustments Explained in Section 92A of Indian Law.</h1> Article 9 of the OECD Model Tax Convention addresses taxation of associated enterprises. It applies when enterprises in different Contracting States have shared management, control, or capital, and conditions between them differ from those between independent enterprises. In such cases, profits that should have accrued to one enterprise but did not due to these conditions can be included and taxed. If one state taxes profits that would have accrued under independent conditions, the other state must adjust its tax accordingly. The UN Model Convention mirrors this, with an exception for cases involving fraud or gross negligence. Indian law addresses these issues under Section 92A of the Income Tax Act, 1961.
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