Transfer pricing adjustments: reallocate profits for non-arm's-length intercompany terms, requiring reciprocal tax adjustment.

Interrelated enterprises whose commercial or financial conditions differ from those between independent enterprises may have profits reallocated and taxed by the Contracting State applying the arm's length principle. If those reallocated profits are also taxed in the other Contracting State, that other State must make an appropriate adjustment to its tax, with competent authorities consulting and having regard to the Agreement's provisions to prevent double taxation.

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