The heading for article 9 in most of Canada's treaties, such as the Canada-Denmark treaty, is called 'associated enterprises'. In the Canada-US treaty it is called 'related persons'.
The intent, however, is similar. To ensure that transactions between associated or related persons (i.e. a parent and subsidiary corporation) take place in the same manner as those that are not related. If you would not have paid someone that you aren't related to for the expenses, those expenses are not going to be permitted for cross-border purposes either.
The article sometimes, but not always, specifies the timing for transfer pricing adjustments to be permitted also. For instance, in the Canada-Denmark treaty the maximum time limit is six years from the end of the taxation year, in the Canada-Egypt treaty the maximum time limit is five years. On the other hand, other treaties, such as the Canada-Australia and the Canada-Norway, leave the timing issue to other articles or to the laws in each country.
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