https://www.taxtmi.com/acts?id=15059 Article 9 treats enterprises with cross-border participation as associated enterprises and permits inclusion in taxable profits where inter-enterprise conditions differ from those between independent enterprises. Where one State taxes profits that would have accrued to an enterprise of the other State under arm's-length conditions, the other State shall make an appropriate adjustment if justified, with regard to the Agreement and following consultation between the competent authorities. en-us Tue, 30 Aug 2011 14:23:53 +0530 Fri, 20 Dec 2024 13:25:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15059 Article 9 treats enterprises with cross-border participation as associated enterprises and permits inclusion in taxable profits where inter-enterprise conditions differ from those between independent enterprises. Where one State taxes profits that would have accrued to an enterprise of the other State under arm's-length conditions, the other State shall make an appropriate adjustment if justified, with regard to the Agreement and following consultation between the competent authorities. Act-Rules DTAA Tue, 30 Aug 2011 14:23:53 +0530 https://www.taxtmi.com/acts?id=15059