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    <description>Article 10 applies the arm&#039;s length principle to Associated Enterprises: where related enterprises enter into conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in the taxable profits of the enterprise that benefited and taxed. If one State taxes such included profits which were taxed in the other State, that other State shall make an appropriate tax adjustment, with competent authorities consulting as necessary to determine the adjustment.</description>
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      <description>Article 10 applies the arm&#039;s length principle to Associated Enterprises: where related enterprises enter into conditions differing from those between independent enterprises, profits that would have accrued but for those conditions may be included in the taxable profits of the enterprise that benefited and taxed. If one State taxes such included profits which were taxed in the other State, that other State shall make an appropriate tax adjustment, with competent authorities consulting as necessary to determine the adjustment.</description>
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