https://www.taxtmi.com/acts?id=14998 Article 9 permits inclusion in taxable profits of amounts that would have accrued to an enterprise but for non arm's length conditions between associated enterprises where one enterprise participates in the management, control or capital of the other or where the same persons participate in both. It implements the arm's length principle by allowing reallocation of profits to reflect independent enterprise conditions. Where one State taxes such adjusted profits, the other State must make an appropriate corresponding tax adjustment, with competent authorities consulting as necessary to coordinate adjustments and respect the Agreement's provisions. en-us Tue, 30 Aug 2011 12:28:25 +0530 Tue, 26 Nov 2024 16:24:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14998 Article 9 permits inclusion in taxable profits of amounts that would have accrued to an enterprise but for non arm's length conditions between associated enterprises where one enterprise participates in the management, control or capital of the other or where the same persons participate in both. It implements the arm's length principle by allowing reallocation of profits to reflect independent enterprise conditions. Where one State taxes such adjusted profits, the other State must make an appropriate corresponding tax adjustment, with competent authorities consulting as necessary to coordinate adjustments and respect the Agreement's provisions. Act-Rules DTAA Tue, 30 Aug 2011 12:28:25 +0530 https://www.taxtmi.com/acts?id=14998