https://www.taxtmi.com/acts?id=52151 Article 9 permits reallocation of profits between associated enterprises when conditions between them differ from those between independent enterprises, allowing a State to include in taxable profits amounts that would have accrued under an arm's length standard. If one State taxes such adjusted profits, the other State must make an appropriate adjustment to relieve double taxation, with due regard to the Agreement and consultation between competent authorities where necessary. en-us Tue, 04 Nov 2025 17:27:03 +0530 Tue, 04 Nov 2025 17:27:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=52151 Article 9 permits reallocation of profits between associated enterprises when conditions between them differ from those between independent enterprises, allowing a State to include in taxable profits amounts that would have accrued under an arm's length standard. If one State taxes such adjusted profits, the other State must make an appropriate adjustment to relieve double taxation, with due regard to the Agreement and consultation between competent authorities where necessary. Act-Rules DTAA Tue, 04 Nov 2025 17:27:03 +0530 https://www.taxtmi.com/acts?id=52151