Associated enterprise adjustments require inclusion of non arm's length profits and corresponding tax adjustment by the other State. Where related enterprises impose non-arm's-length conditions, profits that would have accrued but for those conditions may be included in the affected enterprise's taxable profits and taxed by the Contracting State. If those profits are taxed in both States, the other State shall make an appropriate corresponding tax adjustment, with competent authorities consulting each other and having regard to the Convention's other provisions.
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Provisions expressly mentioned in the judgment/order text.
Associated enterprise adjustments require inclusion of non arm's length profits and corresponding tax adjustment by the other State.
Where related enterprises impose non-arm's-length conditions, profits that would have accrued but for those conditions may be included in the affected enterprise's taxable profits and taxed by the Contracting State. If those profits are taxed in both States, the other State shall make an appropriate corresponding tax adjustment, with competent authorities consulting each other and having regard to the Convention's other provisions.
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