Associated enterprises: arm's length adjustments permit inclusion of diverted profits and require corresponding tax adjustments by the other State. Where enterprises of the two Contracting States are associated by participation in management, control or capital, transactions departing from those between independent enterprises may be disregarded and profits that would have accrued under the arm's length principle may be included in taxable profits and taxed. If one State taxes such included profits already charged to tax in the other State, that other State shall make an appropriate tax adjustment, with due regard to the Agreement and consultation between competent authorities.