Associated Enterprises under DTA Agreements

In order to plug loop holes for tax evasion, there is generally a separate article in DTA agreement, which provides for taxing the notional income, deemed to arise on account of an enterprise of one contracting state, participating directly/indirectly in the management of another enterprise in the other contractingstate or, where some persons participate directly or indirectly in both the enterprises, under conditions different from those existing between the independent enterprises.