Associated enterprises: transfer pricing adjustments permit inclusion of attributable profits and corresponding tax relief via consultation.

Article 9 addresses associated enterprises where participation in management, control or capital leads to non-arm's-length conditions; profits that would have accrued but for those conditions may be included in the taxable profits of the affected enterprise and taxed. Where one State taxes such included profits, the other State may make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between the competent authorities if necessary.

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