Associated enterprises rules allow arm's length profit adjustments and require corresponding tax relief to prevent double taxation. Associated enterprises rules permit a Contracting State to include in an enterprise's taxable profits amounts that would have accrued had related-party conditions been those between independent enterprises. If one State taxes adjusted profits that would otherwise accrue to an enterprise in the other State, that other State must make an appropriate corresponding adjustment to prevent double taxation, with consultation between competent authorities. The corresponding adjustment obligation is excluded where a final ruling imposes a penalty for fraud, gross negligence or wilful default related to the adjustment.