Associated enterprises: pricing deviations can be adjusted so profits are included and taxed as between independent enterprises.

An enterprise of one Contracting State participating in the management, control or capital of an enterprise of the other Contracting State, or where the same persons participate in enterprises of both States, is treated as associated. If conditions between such associated enterprises differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in the profits of the enterprise and taxed accordingly.

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