...another Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...of that enterprise and taxed accordingly. 2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly...

...enterprises in their commercial or financial relations that differ from those that would have been made between independent enterprises, then any profits...profits of that enterprise and taxed accordingly. Article 7, but not article 9, explicitly qualifies the commitment of the model to pure ‘arm's length'...

...charged in ' ' Article 9 states that: 'Where conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...profits of that enterprise and taxed accordingly.' 12 This extract is meant for general information only and should not be relied on without further proper...

...other Contracting State, and in either case conditions are made or imposed between thé rwo enterprises in their commercial or financial relations which differ...any profits which would, but for those conditions, hâve accrued to one of thé enterprises, but, by reason of those conditions, hâve not so accrued,...

...between the two enterprises in their commercial or financial relations that differ from those that would be made between independent enterprises, then...conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included 1. Where a) a resident of a Contracting...

...other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...be made between independent enterprises, then any income which would, but for those conditions, have accrued to one of the enterprises, but, by reason...

...follows: OECD Guidelines 1995, Glossary: ". . . conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...profits of that enterprise and taxed accordingly. " Exhibit 1: Determination of Transfer Price "Diamond" Functional Analysis (Analysis of Activities...

...Article 9 of the OECD Model Tax Convention, "where conditions are made or imposed between two enterprises in their commercial or financial relations which differ...profits of that enterprise and taxed accordingly". Main Sources of Basic Data Concerning Globalisation Indicators Main sources of basic data 1. The main...

...analyzing transfer pricing in this way: [W]here conditions are made or imposed between two enterprises in their commercial or financial relations which differ...included in the profits of that enterprise and taxed accordingly.3 2. Reg. § 1.482-l(b)(l). The OECD makes some additional interesting observations relative...

...arm's-length standard outlined in the OECD Guidelines. The OECD defines arm's-length as the following: enterprises, then any profits which would, but for...the profits of that enterprise and taxed accordingly (OECD, 2001, p. Gl). Penalties are imposed for failure to comply with the transfer pricing rules and...