Associated enterprises transfer pricing adjustments: profit inclusion by one state and corresponding tax adjustment by the other.

Article 9 permits inclusion in taxable profits where associated enterprises make commercial or financial conditions differing from independent enterprises, allowing profits that would otherwise have accrued to be taxed in the State of that enterprise. Where one State taxes such adjusted profits, the other State must make an appropriate corresponding adjustment, with due regard to the Agreement and subject to consultation between the competent authorities.

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