International - Corresponding Adjustment and Its Interaction with the Mutual Agreement Procedure under Article 25 of the OECD Model
- P. Das
- International Transfer Pricing Journal, 2019 (Volume 26), No 1
- 28 December 2018
Primary transfer pricing adjustments under article 9(1) of the OECD Model in the case of associated enterprises trigger economic double taxation as the same income has already been subject to taxation in the hands of the associated enterprises in other contracting states. The author examines the existing relief mechanism of economic double taxation under article 9(2) of the OECD Model and its interaction with article 25 thereof to find out its effectiveness and suggests possible measures to remedy the shortcomings.