https://www.taxtmi.com/acts?id=20118 Article 9 permits reallocation and inclusion in taxable profits where enterprises of the Contracting States are associated through management, control or capital and conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one State includes and taxes such reallocated profits that have also been taxed in the other State, that other State shall make an appropriate adjustment to its tax on those profits, with due regard to the Agreement and consultation between competent authorities. en-us Fri, 04 Dec 2015 14:17:27 +0530 Mon, 02 Sep 2024 15:35:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=20118 Article 9 permits reallocation and inclusion in taxable profits where enterprises of the Contracting States are associated through management, control or capital and conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one State includes and taxes such reallocated profits that have also been taxed in the other State, that other State shall make an appropriate adjustment to its tax on those profits, with due regard to the Agreement and consultation between competent authorities. Act-Rules DTAA Fri, 04 Dec 2015 14:17:27 +0530 https://www.taxtmi.com/acts?id=20118