Associated enterprise adjustments reallocate profits when controlled relations differ from arm's length, triggering corresponding tax adjustments.

Where related enterprises impose conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in and taxed in the State where reallocation occurs; if such profits are also taxed in the other State, that other State shall make an appropriate tax adjustment, with competent authorities consulting as necessary to determine the adjustment in light of the Agreement's provisions.

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