Associated enterprises and arm's-length adjustments govern allocation of profits and cross-border tax adjustments. Article 9 treats enterprises with cross-border participation as associated enterprises and permits inclusion in taxable profits where inter-enterprise conditions differ from those between independent enterprises. Where one State taxes profits that would have accrued to an enterprise of the other State under arm's-length conditions, the other State shall make an appropriate adjustment if justified, with regard to the Agreement and following consultation between the competent authorities.