Arm's length principle applied: adjustments to profits where controlled conditions differ between related enterprises, with reciprocal tax adjustment.

Where enterprises are related through participation in management, control or capital or by common persons and conditions between them differ from independent-entity terms, 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 one State taxes such included profits that have also been taxed in the other State, that other State shall make an appropriate corresponding adjustment, with due regard to the Agreement and consultation between the competent authorities.

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