https://www.taxtmi.com/acts?id=43948 Associated enterprises rules permit a Contracting State to include in an enterprise's taxable profits amounts that would have accrued had related-party conditions been those between independent enterprises. If one State taxes adjusted profits that would otherwise accrue to an enterprise in the other State, that other State must make an appropriate corresponding adjustment to prevent double taxation, with consultation between competent authorities. The corresponding adjustment obligation is excluded where a final ruling imposes a penalty for fraud, gross negligence or wilful default related to the adjustment. en-us Wed, 28 Aug 2024 12:44:53 +0530 Thu, 26 Dec 2024 16:06:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=43948 Associated enterprises rules permit a Contracting State to include in an enterprise's taxable profits amounts that would have accrued had related-party conditions been those between independent enterprises. If one State taxes adjusted profits that would otherwise accrue to an enterprise in the other State, that other State must make an appropriate corresponding adjustment to prevent double taxation, with consultation between competent authorities. The corresponding adjustment obligation is excluded where a final ruling imposes a penalty for fraud, gross negligence or wilful default related to the adjustment. Act-Rules DTAA Wed, 28 Aug 2024 12:44:53 +0530 https://www.taxtmi.com/acts?id=43948