Associated enterprises transfer pricing: profits may be reallocated where controlled conditions differ and reciprocal tax adjustments required.

Article 9 allows reallocation of profits where enterprises of Contracting States are associated and conditions between them differ from arm's length terms, permitting inclusion and taxation of profits that would have accrued under independent conditions. It mandates an appropriate corresponding adjustment by the other State where it has already taxed such profits, with due regard to the Convention and consultation between competent authorities if necessary.

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