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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Associated enterprises: differing commercial conditions can trigger profit reallocation and reciprocal tax adjustments between States.</h1> When enterprises of the Contracting States are related by participation in management, control or capital, and conditions between them differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in taxable profits and taxed. If one State taxes such included profits which are also taxed in the other State, the other State shall make an appropriate tax adjustment, with due regard to the Agreement and consultation between the competent authorities.

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