Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Republic of Tunisia : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-16-90

Cover Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Republic of Tunisia : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-16-90
Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Republic of Tunisia : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-16-90
United States. Congress. Joint Committee On Taxation
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Rules similar to the rules provided in Article 8 apply to the tax-| ation of gains from the disposition of ships or aircraft operated in| international traffic (Article 13(4)). I Article 9. Associated Enterprises I The proposed treaty, like most other U.S. tax treaties, contains!
an arm's-length pricing provision, similar to Code section 482, that' recognizes the right of each country to make an allocation of!
income, deductions, credits, or allowances to that country in the' case of transactio
...ns between related persons to reflect the condi- j tions and arrangements that would have been made between inde- !
pendent persons. i For purposes of the proposed treaty, a person is related to an- 1 other person if either person owns or controls directly or indirectly i the other, or if any third person or persons own or control directly or indirectly both related persons.
If, pursuant to this article, one country includes in the profits of its resident, and taxes accordingly, profits on which a resident of the other country has been subjected to tax in that other country, then the other country, if it agrees that the adjustment reflects arm s-length principles, is to make a correlative adjustment to the amount of the tax charged on its resident on those profits.


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