https://www.taxtmi.com/acts?id=18905 Article 9 applies the arm's length principle to related-party transactions: where conditions between related enterprises differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits and taxed. The Article also mandates a corresponding adjustment by the other Contracting State when profits so included have been charged to tax there, with consultation between competent authorities to determine appropriate adjustments and account for other Agreement provisions. en-us Tue, 12 Aug 2014 13:39:22 +0530 Tue, 26 Nov 2024 18:03:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18905 Article 9 applies the arm's length principle to related-party transactions: where conditions between related enterprises differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits and taxed. The Article also mandates a corresponding adjustment by the other Contracting State when profits so included have been charged to tax there, with consultation between competent authorities to determine appropriate adjustments and account for other Agreement provisions. Act-Rules DTAA Tue, 12 Aug 2014 13:39:22 +0530 https://www.taxtmi.com/acts?id=18905