https://www.taxtmi.com/acts?id=37640 Article 9 permits inclusion in taxable profits where conditions between related cross border enterprises differ from those between independent enterprises, allowing profits that would have accrued but for those conditions to be taxed. If one Contracting State taxes such adjusted profits, the other State must make an appropriate tax adjustment and the competent authorities shall consult, taking into account other provisions of the Agreement, thereby applying the arm's length principle and coordinating to avoid double taxation from transfer pricing adjustments. en-us Thu, 19 Sep 2019 12:13:21 +0530 Tue, 26 Nov 2024 17:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37640 Article 9 permits inclusion in taxable profits where conditions between related cross border enterprises differ from those between independent enterprises, allowing profits that would have accrued but for those conditions to be taxed. If one Contracting State taxes such adjusted profits, the other State must make an appropriate tax adjustment and the competent authorities shall consult, taking into account other provisions of the Agreement, thereby applying the arm's length principle and coordinating to avoid double taxation from transfer pricing adjustments. Act-Rules DTAA Thu, 19 Sep 2019 12:13:21 +0530 https://www.taxtmi.com/acts?id=37640