Arm's length adjustments: reallocate and tax profits of associated enterprises, with corresponding adjustments by the other State.

Article 9 applies the arm's length principle to associated enterprises where direct or indirect participation in management, control or capital, or common participation, leads to non arm's length conditions; profits that would have accrued absent those conditions may be included in taxable profits and taxed. Paragraph 1 of Article 17 of the MLI supersedes this Convention provision by requiring the other Contracting State to make an appropriate corresponding adjustment when one State taxes such reallocated profits, with due regard to other provisions and consultation between competent authorities.

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