https://www.taxtmi.com/acts?id=45639 Article 10 treats enterprises as associated where one participates in the management, control or capital of an enterprise in the other Contracting State, or where the same persons participate in both, and permits reallocation of profits that would have accrued but for non-arm's-length conditions so they may be taxed accordingly. Paragraph 1 of MLI Article 17 requires corresponding adjustments: when one State taxes profits included on an arm's-length basis that reduce profits in the other State, that other State shall make an appropriate adjustment, with due regard to the Convention and after competent authority consultation. en-us Wed, 23 Oct 2024 12:25:36 +0530 Wed, 23 Oct 2024 12:25:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45639 Article 10 treats enterprises as associated where one participates in the management, control or capital of an enterprise in the other Contracting State, or where the same persons participate in both, and permits reallocation of profits that would have accrued but for non-arm's-length conditions so they may be taxed accordingly. Paragraph 1 of MLI Article 17 requires corresponding adjustments: when one State taxes profits included on an arm's-length basis that reduce profits in the other State, that other State shall make an appropriate adjustment, with due regard to the Convention and after competent authority consultation. Act-Rules DTAA Wed, 23 Oct 2024 12:25:36 +0530 https://www.taxtmi.com/acts?id=45639