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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 rules permit profit adjustments where controlled conditions diverge from arm's length outcomes, requiring corresponding tax relief.</h1> Associated enterprises rules permit inclusion and taxation of profits where inter-enterprise conditions differ from those between independent enterprises, causing profits to be shifted or reduced; such profits may be included in the taxable income of the affected enterprise. If one Contracting State taxes adjusted profits that correspond to profits taxed in the other State, that other State shall make an appropriate adjustment to the tax charged, with due regard to the Convention and consultation between the competent authorities.

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