Associated enterprises principle: include non arm's length profits in taxable income and coordinate relief across jurisdictions. Associated enterprises rules permit inclusion in taxable profits of amounts that would have accrued but for conditions between related enterprises that differ from those between independent enterprises; this applies where one enterprise participates in the management, control or capital of the other or common persons control both. If one Party taxes such included profits already charged in the other Party, that other Party must make an appropriate adjustment to its tax, with due regard to the Treaty and consultation between the competent authorities.