Double Taxation Agreement

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ASSOCIATED ENTERPRISES
ARTICLE 9

52	Scope.
53.	Associated enterprises.
53.1	Management.
53.2	Control.
53.3	‘Control and management’.
54.	General rule of computing of Income of associated enterprises and their deviations.
54.1	Arm’s length and shifting of profits.
54.1-1	Income splitting.
54.1-2	Transfer pricing.
54.1-3	Treaty shopping.
54.1-4	Royalty and technical fee.
54.1-5	Capitalisation and loan financing.
54.2	Methods for determining arm’s length price of goods.
54.2-1	Arm’s length method is the most favoured.
54.2-2	Arm’s length method and intangible services.
54.2-3	Arm’s length method under Pakistani Income Tax Ordinance, 1979.
54.3	Relief form taxation on account of arm’s length method.