https://www.taxtmi.com/acts?id=45317 Article 9 permits a Contracting State to include in an enterprise's taxable profits amounts that would have accrued but for conditions between associated enterprises that deviate from those between independent enterprises, restoring an arm's length allocation. If one State taxes such adjusted profits already taxed in the other State, the other State must make an appropriate corresponding adjustment, with competent authorities consulting each other and considering the Convention's other provisions to coordinate relief and avoid double taxation. en-us Fri, 18 Oct 2024 11:54:34 +0530 Fri, 18 Oct 2024 11:54:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45317 Article 9 permits a Contracting State to include in an enterprise's taxable profits amounts that would have accrued but for conditions between associated enterprises that deviate from those between independent enterprises, restoring an arm's length allocation. If one State taxes such adjusted profits already taxed in the other State, the other State must make an appropriate corresponding adjustment, with competent authorities consulting each other and considering the Convention's other provisions to coordinate relief and avoid double taxation. Act-Rules DTAA Fri, 18 Oct 2024 11:54:34 +0530 https://www.taxtmi.com/acts?id=45317