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    <description>Where related enterprises apply conditions that differ from those between independent enterprises, any profits that would have accrued but for those conditions may be included in the profits of the affected enterprise and taxed accordingly. If one State taxes such reallocated profits which have also been taxed in the other State, that other State shall make an appropriate adjustment where it considers it justified, with regard to the Agreement&#039;s provisions and after consultation between competent authorities if necessary.</description>
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