Associated enterprises transfer pricing: adjustments permit inclusion of shifted profits and require corresponding tax relief by the other State.

Article 9 permits transfer pricing adjustments where linked enterprises' intercompany conditions differ from arm's length dealings; a State may include in taxable profits amounts that would have accrued under independent enterprise conditions and tax them. If such inclusion results in taxation of profits already taxed in the other Contracting State, that other State shall make an appropriate tax adjustment, with competent authorities consulting as necessary and having regard to the Agreement's other provisions.

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