a) an enterprise of a Contracting State participates directly or indirectly in the
management, control or capital of an enterprise of the other Contracting State, or
b) the same persons participate directly or indirectly in the management, control or
capital of an enterprise of a Contracting State and an enterprise of the other
Contracting State,
and in either case conditions are made or imposed between the two enterprises in their
commercial or financial relations which differ from those which would be made between
independent enterprises, then any profits which would, but for those conditions, have accrued
to one of the enterprises, but, by reason of those conditions, have not so accrued, may be
included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State—and taxes
accordingly—profits on which an enterprise of the other Contracting State has been charged
to tax in that other State and the profits so included are profits which would have accrued to
the enterprise of the first-mentioned State if the conditions made between the two enterprises
had been those which would have been made between independent enterprises, then that
other State shall make an appropriate adjustment to the amount of the tax charged therein on
those profits. In determining such adjustment, due regard shall be had to the other provisions
of this Convention and the competent authorities of the Contracting States shall if necessary
consult each other.
Citation to select or copy
United Kingdom / India; Official amended convention publication (currentness unverified) · 1993-convention-amended-2013-publication; edition 1993-convention-amended-2013-publication; article 10; English; unreviewed source text, current applicability unverified; /editions/in-gb-1993-amended-2013-official/en/articles/10/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
Source & edition
Official amended convention publication (currentness unverified) · 1993-convention-amended-2013-publication
Unknown actual amended PDF publication; filename 2013 is amendment wording, not a verified publication date
Languages recorded in source metadata: English, हिन्दी. This is not a promise of available text or a translation.
Edition notes and known limitations
The signed closing has been separated from Article 31 by an exact retained-source boundary; no wording or PDF bytes changed. The retained extraction ledger predates this navigation repair.
Research observed on the related SI made page: 'Made 20th July 1993' and 'At the Court at Buckingham Palace, the 20th day of July 1993'. This is the related UK domestic enabling instrument made date, NOT the publication date of the amended PDF or the convention signed date. Filename contains 'as_amended_in_2013_-_in_force'; that is filename status wording only, not independently verified current legal status. Search-result title reported 'UK/India Double Taxation Convention Signed 25 January 1993', not verified within a fetched document and not asserted as a verified signed-date field. No revocation noted on the made page is not proof of currentness. Product generation additionally verifies the underlying convention signature clause in the retained native transcription with exact offsets; this does not date the amended publication or prove currentness.
official amended source publication kept separate; no product-generated consolidation or currentness proof
Native extraction blocks are navigation references, not verified legal paragraphs. Page references are extraction-page slots, not visually verified correspondence. Front matter and material outside article navigation remain in the complete transcription.