https://www.taxtmi.com/acts?id=4221 Article 9 permits reallocation of profits where related enterprises transact on terms differing from those between independent enterprises: profits that would have accrued under arm's length conditions may be included in taxable income and taxed. Where one State taxes such included profits that have been charged in the other State, that other State shall make an appropriate adjustment, taking into account the Convention and following consultation between the competent authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 11 Oct 2024 16:28:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4221 Article 9 permits reallocation of profits where related enterprises transact on terms differing from those between independent enterprises: profits that would have accrued under arm's length conditions may be included in taxable income and taxed. Where one State taxes such included profits that have been charged in the other State, that other State shall make an appropriate adjustment, taking into account the Convention and following consultation between the competent authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4221