Associated enterprises transfer pricing: arm's-length adjustments allocate and tax profits between Contracting States to prevent profit shifting. Article 9 treats associated enterprises and permits inclusion in taxable profits where intercompany conditions depart from arm's-length conditions, allowing a State to tax profits that would have accrued absent those conditions. It requires the other State to make appropriate adjustments to prevent double taxation where those profits are taxed there, with adjustments determined by regard to the treaty and consultation between competent authorities.