Associated enterprises

The concept of associated enterprises applies typically in tax treaties and encapsulates the arm’s-length principle. An enterprise of one contracting state may engage in commercial dealings with an enterprise of the other contracting state that is under common control, management, or ownership. If the two enterprises deal under conditions that would not have been imposed on an independent enterprise, a contracting state may include as taxable profits of the enterprise amounts that would have been derived by the enterprise in an arm’s-length relationship.

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