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ARTICLE 9

U.S. Income Tax Treaty — Venezuela Income Tax Treaty - 1999 · 2026-10-03 edition · updated 2026-10-04 · United States

Associated Enterprises

  1. Where:

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 that would be made between independent enterprises, then any profits that, but for those conditions, would 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.

  1. 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 that would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those that would have been made between independent enterprises, then that other State, if it agrees with such adjustment, shall make a corresponding adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be paid to the

other provisions of this Convention and the competent authorities of the Contracting States shall if necessary consult each other.

  1. The provisions of paragraph 1 shall not limit any provisions of the law of either Contracting State that permit the distribution, apportionment, or allocation of income, deductions, credits, or allowances between persons, whether or not residents of a Contracting State, owned or controlled directly or indirectly by the same interests when necessary in order to prevent evasion of taxes or clearly to reflect the income of any such persons.

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▸Contents — U.S. Income Tax Treaty — Venezuela Income Tax Treaty - 1999
U.S. Income Tax Treaty — Venezuela Income Tax Treaty - 1999

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