Arm's length principle permits transfer pricing adjustments and corresponding tax adjustments to prevent profit shifting. Where enterprises of the two Contracting States are linked by participation or common persons and their inter-enterprise conditions differ from those between independent enterprises, profits that would have accrued but for those conditions may be included in and taxed as the profits of the enterprise to which they would have accrued; if such profits are taxed in one State while also being charged to tax in the other, the other State shall make an appropriate adjustment, with due regard to the Convention and consultation between competent authorities.