https://www.taxtmi.com/acts?id=4819 Article 9 requires that transactions between enterprises related by management, control or capital be measured against conditions which independent enterprises would make; if differing conditions cause profits to be diverted, those profits may be included in the taxable profits of the affected enterprise and taxed. Where one State taxes such included profits that have also been charged to tax in the other State, that other State shall make an appropriate adjustment, with due regard to the agreement and consultation between the competent authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 17:15:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4819 Article 9 requires that transactions between enterprises related by management, control or capital be measured against conditions which independent enterprises would make; if differing conditions cause profits to be diverted, those profits may be included in the taxable profits of the affected enterprise and taxed. Where one State taxes such included profits that have also been charged to tax in the other State, that other State shall make an appropriate adjustment, with due regard to the agreement and consultation between the competent authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4819