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To better understand this concept, it is helpful to explain the notion of “associated…
In Turkish legislation, Article 13, paragraph 2 of the Corporate Tax Law clarifies…
Summarizing the concept of corresponding adjustment: it refers to the reduction of…
Corresponding adjustments can be made in two ways. The first method involves recalculating…
This mechanism is enabled by the provisions in Article 9, paragraph 2 of the OECD…
The rationale behind introducing the concept of corresponding adjustments is to prevent…
Corresponding adjustments are not limited to secondary adjustments in the second…
Under Article 9 of the OECD Model, the provisions of the MAP can be used for adjustments…
If one of the Contracting States accepts a corresponding adjustment, it must clarify…
Like the MAP provisions, corresponding adjustments are not mandatory. A Contracting…
The UN Model also includes provisions on corresponding adjustments similar to those…
Weaknesses of the MAP, and thus corresponding adjustments, include that Contracting…
Issues related to corresponding adjustments and MAP can be categorized into four…
