Arm's length principle allows inclusion of adjusted intercompany profits and a corresponding tax adjustment if agreed.

Article 9 applies the Arm's length principle to associated enterprises: where inter-company conditions differ from those between independent enterprises, profits that would have accrued but for those conditions may be included and taxed. If one State makes such an adjustment and the other State agrees it is justified in principle and amount, that other State shall make an appropriate corresponding tax adjustment, with competent authorities consulting each other as necessary.

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