https://www.taxtmi.com/acts?id=4790 Article 9 allows reallocation of profits where enterprises of Contracting States are associated and conditions between them differ from arm's length terms, permitting inclusion and taxation of profits that would have accrued under independent conditions. It mandates an appropriate corresponding adjustment by the other State where it has already taxed such profits, with due regard to the Convention and consultation between competent authorities if necessary. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 21 Nov 2024 12:21:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4790 Article 9 allows reallocation of profits where enterprises of Contracting States are associated and conditions between them differ from arm's length terms, permitting inclusion and taxation of profits that would have accrued under independent conditions. It mandates an appropriate corresponding adjustment by the other State where it has already taxed such profits, with due regard to the Convention and consultation between competent authorities if necessary. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4790