Associated enterprises rule allows reallocation of profits when related party terms diverge from arm's length norms.

Associated enterprises provisions apply where one enterprise participates in the management, control or capital of another, or where the same persons participate in enterprises in both Contracting States, and where commercial or financial conditions between them differ from those between independent enterprises. If such non arm's length conditions cause profits that would otherwise have accrued to an enterprise not to accrue, those profits may be included in the enterprise's taxable income and taxed accordingly.

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