Arm's length principle permits profit allocation adjustments between associated enterprises and requires corresponding tax adjustments by the other State.

Where controlled relationships cause conditions differing from those between independent enterprises, profits that would have accrued but for such conditions may be included in an enterprise's taxable profits to reflect the arm's length principle. If one Contracting State taxes those adjusted profits, the other State shall make an appropriate corresponding adjustment to its tax, with due regard to the Agreement and consultation between competent authorities.

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