https://www.taxtmi.com/acts?id=6191 Article 9 provides that where enterprises of the two Contracting States are associated through participation in management, control or capital, or common persons participate in both, and conditions between them differ from those between independent enterprises, any profits which would have accrued but for those conditions may be included in the profits of the relevant enterprise and taxed accordingly as a transfer-pricing adjustment to reflect arm's-length results. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 22 Nov 2024 18:22:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6191 Article 9 provides that where enterprises of the two Contracting States are associated through participation in management, control or capital, or common persons participate in both, and conditions between them differ from those between independent enterprises, any profits which would have accrued but for those conditions may be included in the profits of the relevant enterprise and taxed accordingly as a transfer-pricing adjustment to reflect arm's-length results. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6191