https://www.taxtmi.com/acts?id=18002 Article 9 permits reallocation of profits when conditions between enterprises under common control differ from those between independent enterprises, allowing a Contracting State to include in taxable profits amounts that would have accrued absent such conditions, applying the arm's length principle. If such reallocation results in double taxation because the other State has already taxed those profits, the other State must make an appropriate adjustment after consultation between competent authorities, taking account of the Agreement's provisions. en-us Mon, 22 Jul 2013 16:43:16 +0530 Mon, 18 Nov 2024 12:09:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18002 Article 9 permits reallocation of profits when conditions between enterprises under common control differ from those between independent enterprises, allowing a Contracting State to include in taxable profits amounts that would have accrued absent such conditions, applying the arm's length principle. If such reallocation results in double taxation because the other State has already taxed those profits, the other State must make an appropriate adjustment after consultation between competent authorities, taking account of the Agreement's provisions. Act-Rules DTAA Mon, 22 Jul 2013 16:43:16 +0530 https://www.taxtmi.com/acts?id=18002