https://www.taxtmi.com/acts?id=6114 Article 10 permits inclusion in taxable profits where enterprises with management, control or capital links adopt conditions differing from those between independent enterprises, so that profits that would have accrued but for those conditions may be taxed. Where information is inadequate, each State may exercise statutory discretion or make an estimate of tax liability, but such determinations must, as far as available information permits, accord with the principle of attributing profits as between independent enterprises; amounts so determined may be amended when adequate information is provided. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 09 Dec 2024 12:38:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6114 Article 10 permits inclusion in taxable profits where enterprises with management, control or capital links adopt conditions differing from those between independent enterprises, so that profits that would have accrued but for those conditions may be taxed. Where information is inadequate, each State may exercise statutory discretion or make an estimate of tax liability, but such determinations must, as far as available information permits, accord with the principle of attributing profits as between independent enterprises; amounts so determined may be amended when adequate information is provided. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6114