Associated enterprises transfer pricing adjustments enable corresponding tax relief to prevent double taxation between Contracting States. Where enterprises of Contracting States are related by participation in management, control or capital and inter-enterprise conditions deviate from those between independent enterprises, profits that would have accrued absent those conditions may be included and taxed. If such included profits are taxed in one State and also charged in the other State, the other State shall make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between competent authorities.
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Provisions expressly mentioned in the judgment/order text.
Associated enterprises transfer pricing adjustments enable corresponding tax relief to prevent double taxation between Contracting States.
Where enterprises of Contracting States are related by participation in management, control or capital and inter-enterprise conditions deviate from those between independent enterprises, profits that would have accrued absent those conditions may be included and taxed. If such included profits are taxed in one State and also charged in the other State, the other State shall make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between competent authorities.
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