Associated enterprises adjustment: arm's-length profit allocation can be included for taxation and other State must make corresponding tax adjustment.

Article 9 permits reallocation and inclusion in taxable profits where enterprises of the Contracting States are associated through management, control or capital and conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one State includes and taxes such reallocated profits that have also been taxed in the other State, that other State shall make an appropriate adjustment to its tax on those profits, with due regard to the Agreement and consultation between competent authorities.

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