What OECD Model Tax Convention Article 9 - Associated Enterprises and Arm's Length Principle: Conditions for Adjustment, Primary Adjustment, Corresponding Adjustment, Mutual Agreement Procedure and Secondary Adjustments requires
This regulation requires that transactions between associated enterprises be priced as if they were conducted between independent parties (arm’s length principle) under Article 9(1) of the OECD Model Tax Convention. It applies to multinational enterprises and tax authorities in determining appropriate transfer pricing for cross-border transactions.
Pillar: Tax & Transfer Pricing · Authority: Organisation for Economic Co-operation and Development (OECD) · Version: 1.0.0 · Last updated:
Primary source: https://www.oecd.org/tax/treaties/oecd-model-tax-convention-on-income-and-on-capital-2017-full-version-9789264306097-en.htm
SHA-256 integrity: a134ac8fc89248e3fcab78dfacebf5e82f3629e196bf08670ef36991c44ab1e4
Primary Citations — 5 traced to source
- OECD Model Tax Convention on Income and on Capital, Article 9(1) - Associated Enterprises
- OECD Model Tax Convention on Income and on Capital, Article 9(2) - Mutual Agreement Procedure for Adjustments
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