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    <title>Associated Enterprises</title>
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    <description>Where enterprises of the Contracting States are connected by participation in management, control or capital, or by common persons, and conditions between them differ from those that would be made between independent enterprises, profits that would have accrued but for those conditions may be included in and taxed as the enterprise&#039;s profits. If one State taxes such reallocated profits that have been charged to tax in the other State, the other State shall make an appropriate adjustment to its tax, with due regard to the Agreement&#039;s provisions and consultation between competent authorities.</description>
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      <description>Where enterprises of the Contracting States are connected by participation in management, control or capital, or by common persons, and conditions between them differ from those that would be made between independent enterprises, profits that would have accrued but for those conditions may be included in and taxed as the enterprise&#039;s profits. If one State taxes such reallocated profits that have been charged to tax in the other State, the other State shall make an appropriate adjustment to its tax, with due regard to the Agreement&#039;s provisions and consultation between competent authorities.</description>
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