https://www.taxtmi.com/acts?id=19345 Article 9 provides that where enterprises of the Contracting States are linked by control or common participation and conditions between them differ from those between independent enterprises, profits affected by those non-arm's length conditions may be included and taxed in the enterprise to which they would have accrued. If one State taxes such reallocated profits, the other State must make an appropriate adjustment to avoid economic double taxation, with due regard to the Agreement and consultation between competent authorities if necessary. en-us Fri, 20 Mar 2015 16:15:49 +0530 Wed, 13 Nov 2024 16:39:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=19345 Article 9 provides that where enterprises of the Contracting States are linked by control or common participation and conditions between them differ from those between independent enterprises, profits affected by those non-arm's length conditions may be included and taxed in the enterprise to which they would have accrued. If one State taxes such reallocated profits, the other State must make an appropriate adjustment to avoid economic double taxation, with due regard to the Agreement and consultation between competent authorities if necessary. Act-Rules DTAA Fri, 20 Mar 2015 16:15:49 +0530 https://www.taxtmi.com/acts?id=19345