Article 9 - Associated Enterprises

Article 9 incorporates the arm's-length principle for transactions between associated enterprises. If conditions imposed in dealings between associated enterprises differ from those between independent enterprises, profits which would have accrued absent those conditions may be included and taxed accordingly. Article 9 also contains the corresponding-adjustment provision: when the other State adjusts the profits of its enterprise, this State will make a corresponding adjustment provided it agrees with the principle of the adjustment. India's domestic transfer-pricing rules in Section 257 (formerly Section 92 of IT Act 1961) operate alongside.