Associated enterprises transfer pricing adjustments permit reallocation of non arm's length profits and require corresponding tax relief. Article 9 permits inclusion in taxable profits of amounts that would have accrued but for non arm's length conditions between associated enterprises where one enterprise participates in the management, control or capital of the other, or common persons participate in both. When a State taxes such adjusted profits that have also been taxed in the other State, the other State shall make an appropriate corresponding adjustment, with due regard to the Convention and after consultation between the competent authorities if necessary.