Associated enterprises rule requires arm's-length treatment; profits altered by non-arm's-length conditions may be reallocated and taxed.

Article 9 applies where enterprises of the Contracting States are related by participation in management, control or capital, or by common persons, and where their commercial or financial conditions differ from those between independent enterprises; profits that would have accrued but for those conditions may be included in taxable profits and taxed accordingly. If one State taxes such reallocated profits that have been charged to tax in the other State, that other State shall make an appropriate corresponding adjustment, with due regard to the Convention and with consultation between competent authorities if necessary.

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