https://www.taxtmi.com/acts?id=6051 Article 9 allows a Contracting State to include in the taxable profits of an enterprise amounts that would have accrued but for controlled conditions between associated enterprises, applying arm's length comparisons. If such profits are taxed in both States, the other State must make an appropriate adjustment, with due regard to the Convention and consultation between the competent authorities if necessary. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 03 Dec 2024 11:24:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6051 Article 9 allows a Contracting State to include in the taxable profits of an enterprise amounts that would have accrued but for controlled conditions between associated enterprises, applying arm's length comparisons. If such profits are taxed in both States, the other State must make an appropriate adjustment, with due regard to the Convention and consultation between the competent authorities if necessary. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6051