Associated enterprises transfer pricing adjustments restore arm's length profits and require corresponding tax adjustments by the other State.

Article 9 defines associated enterprises where cross participation in management, control or capital exists or the same persons participate in both enterprises. If 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. When one State includes and taxes such adjusted profits that correspond to profits taxed in the other State, the other State shall make an appropriate corresponding tax adjustment, with due regard to the Convention and consultation between the competent authorities.

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