Associated enterprises: transfer pricing adjustments permit inclusion of shifted profits and require reciprocal tax adjustments. Article 9 permits inclusion in taxable profits of amounts that would have accrued but for non-arm's-length conditions between associated enterprises, and requires the other Contracting State to make an appropriate tax adjustment where both States tax the same profits, with competent authorities consulting as necessary.
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Provisions expressly mentioned in the judgment/order text.
Associated enterprises: transfer pricing adjustments permit inclusion of shifted profits and require reciprocal tax adjustments.
Article 9 permits inclusion in taxable profits of amounts that would have accrued but for non-arm's-length conditions between associated enterprises, and requires the other Contracting State to make an appropriate tax adjustment where both States tax the same profits, with competent authorities consulting as necessary.
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