Associated enterprises: profits may be reallocated for tax purposes when intercompany conditions differ from those between independent enterprises. Associated enterprises are those where one enterprise participates in the management, control or capital of an enterprise of the other Contracting State, or where the same persons participate in enterprises of both States. If conditions between the enterprises differ from those between independent enterprises, any profits that would have accrued but for those conditions may be included in the profits of the affected enterprise and taxed accordingly.