Associated enterprise rules allocate profits when related-party terms deviate from arm's length, enabling tax allocation and adjustments.

When enterprises in the two Contracting States are related by direct or indirect 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 the taxable profits of the enterprise entitled to them. If one State taxes such reallocated profits, the other State shall consider an appropriate corresponding adjustment, with due regard to the Agreement's provisions and consultation between competent authorities as necessary.

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