Common use of Associated Enterprises Clause in Contracts

Associated Enterprises. See treaty text. This contains the usual OECD provisions regarding transfer pricing. Associated enterprises must adopt the arm's length principle in their dealings with each other, and to the extent that they do not, a Contracting State may make an upwards adjustment to taxable profits. Paragraph 2 provides for a corresponding downwards adjustment to taxable profits by the other State providing that the tax authorities in the two States reach agreement. There is express provision for consultation between the tax authorities.

Associated Enterprises. See treaty text. This contains the usual OECD provisions regarding transfer pricing. Associated enterprises must adopt the arm's length principle in their dealings with each other, and to the extent that they do not, a Contracting State may make an upwards adjustment to taxable profits. Paragraph 2 provides for a There is no specific provision requiring the other State to make any corresponding downwards adjustment to taxable profits profits. However, any double taxation resulting from transfer pricing adjustments may be eliminated by the other State providing that the tax authorities in agreement of the two States reach agreement. There is express provision for consultation between using the tax authoritiesMutual Agreement article of this Treaty.

Associated Enterprises. See treaty text. This contains the usual OECD provisions regarding transfer pricing. Associated enterprises must adopt the arm's length principle in their dealings with each other, and to the extent that they do not, a Contracting State may make an upwards adjustment to taxable profits. Paragraph 2 provides for a There is no specific provision requiring the other State to make any corresponding downwards adjustment to taxable profits by although the other State providing that the tax authorities mutual agreement procedure provided for at Article 23 will be used to try to prevent double taxation of profits in the two States reach agreement. There is express provision for consultation between the tax authoritiesthis case.

Associated Enterprises. See treaty text. This contains the usual OECD provisions regarding transfer pricing. Associated enterprises must adopt the arm's length principle in their dealings with each other, and to the extent that they do not, a Contracting State may make an upwards adjustment to taxable profits. Paragraph 2 provides There is no specific requirement for the other State to make a corresponding downwards adjustment to taxable profits profits. However, any double taxation resulting from transfer pricing adjustments may be eliminated by the other State providing that the tax authorities in agreement of the two States reach agreement. There is express provision for consultation between using the tax authoritiesMutual Agreement Article of this Treaty.

Associated Enterprises. See treaty text. This contains the usual OECD provisions regarding transfer pricing. Associated enterprises must adopt the arm's length principle in their dealings with each other, and to the extent that they do not, a Contracting State may make an upwards adjustment to taxable profits. Paragraph 2 provides There is no specific provision for a corresponding downwards adjustment to taxable profits by in the other State providing that the tax authorities in State. However, any double taxation resulting from transfer pricing adjustments may be eliminated by agreement of the two States reach agreement. There is express provision for consultation between using the tax authoritiesMutual Agreement article of this Treaty.

Associated Enterprises. See treaty text. This contains the usual OECD provisions regarding transfer pricing. Associated enterprises must adopt the arm's length principle in their dealings with each other, and to the extent that they do not, a Contracting State may make an upwards adjustment to taxable profits. Paragraph 2 provides for a corresponding The other State is required to make an appropriate downwards adjustment to taxable profits by the other State providing that the tax authorities in the two States reach agreementprofits. There is express provision for consultation on this point between the two tax authorities.