https://www.taxtmi.com/acts?id=14965 Article 9 mandates arm's length adjustments for associated enterprises where participation in management, control or capital or common persons leads to non-arm's length commercial or financial conditions; profits that would have accrued but for those conditions may be included in taxable profits. When one State taxes such adjusted profits already taxed in the other State, the other State must make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between the competent authorities as necessary. en-us Tue, 30 Aug 2011 12:01:44 +0530 Tue, 26 Nov 2024 14:18:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14965 Article 9 mandates arm's length adjustments for associated enterprises where participation in management, control or capital or common persons leads to non-arm's length commercial or financial conditions; profits that would have accrued but for those conditions may be included in taxable profits. When one State taxes such adjusted profits already taxed in the other State, the other State must make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between the competent authorities as necessary. Act-Rules DTAA Tue, 30 Aug 2011 12:01:44 +0530 https://www.taxtmi.com/acts?id=14965