Associated enterprises: arm's length adjustments can reallocate profits and require corresponding tax adjustments by the other state.

Where enterprises linked by direct or indirect participation or common control transact on terms differing from those between independent enterprises, profits that would have accrued but for those non arm's length conditions may be included in the taxable profits of the affected enterprise and taxed. If one State taxes such included profits that have also been taxed in the other State, that other State is to make an appropriate corresponding adjustment, with due regard to the Convention and consultation between competent authorities if necessary.

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