https://www.taxtmi.com/acts?id=4877 Article 9 treats enterprises as associated enterprises where direct or indirect participation in management, control or capital, or common persons' participation, leads to commercial or financial conditions differing from arm's length terms; profits that would have accrued but for such conditions may be included in and taxed as the profits of the affected enterprise. Where one State includes and taxes such reallocated profits, the other State shall make an appropriate adjustment to its tax if it considers the adjustment justified, with due regard to the Convention and consultation between competent authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Dec 2024 11:42:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4877 Article 9 treats enterprises as associated enterprises where direct or indirect participation in management, control or capital, or common persons' participation, leads to commercial or financial conditions differing from arm's length terms; profits that would have accrued but for such conditions may be included in and taxed as the profits of the affected enterprise. Where one State includes and taxes such reallocated profits, the other State shall make an appropriate adjustment to its tax if it considers the adjustment justified, with due regard to the Convention and consultation between competent authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4877