Associated enterprises transfer pricing adjustments require corresponding tax relief by the other State when profits are reallocated.

Article 9 provides that when enterprises of the Contracting States are related and their commercial or financial conditions differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the taxable profits of the affected enterprise. If one State taxes such reallocated profits already taxed in the other State, the other State shall make an appropriate corresponding adjustment, with competent authorities consulting and having due regard to the Agreement's provisions.

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