Associated enterprises adjustment: arm's length deviations permit profit reallocation and corresponding tax adjustment via mutual agreement. Where enterprises of the Contracting States are associated and intercompany conditions differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable income and taxed accordingly. If one State includes and taxes such profits and they have been taxed in the other State, the competent authorities may agree on which profits are attributable under arm's length conditions, and the other State shall make an appropriate corresponding adjustment, having due regard to the Convention's other provisions.