Associated Enterprises. Where - (a) an enterprise of one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States and an enterprise of the other State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 7 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Associated Enterprises. Where -
(a) a. an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) b. the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 7 contracts
Samples: Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Associated Enterprises. Where -Where,
(a) an enterprise of one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States and an enterprise of the other State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any income or profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
Associated Enterprises. Where -Where
(a) an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed operate between the two enterprises in their commercial or financial relations which differ from those which would be made operate between independent enterprises, then any profits which wouldincome which, but for those conditions, might have accrued been expected to accrue to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits income of that enterprise and taxed accordingly.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
Associated Enterprises. Where -
(a) an enterprise of one of the States a territory participates directly or indirectly in the management, control or capital of an enterprise of the other Stateterritory, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a territory and an enterprise of the other Stateterritory, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement
Associated Enterprises. Where -
(a) an enterprise of one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States and an enterprise of the other State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial or financial relations which differ from those which would be made between independent enterprisesenterpirses, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Associated Enterprises. Where -
(a) an An enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the The same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
Associated Enterprises. Where -
(a) an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the managementthemanagement, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, ,and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
Associated Enterprises. Where -Where
(a) an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, . or
(b) the same case persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises enterprise in their commercial or financial relations which differ from those which would be made between independent enterprisesenterprise, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, accrued may be included in the profits of that enterprise enterprises and taxed accordingly.
Appears in 1 contract
Associated Enterprises. Where -
(a) an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of or an enterprise of one of the a Contracting States and an enterprise of the other Contracting State, . and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, would but for those conditions, conditions have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 1 contract
Samples: Double Taxation Agreement
Associated Enterprises. Where -Where-
(a) 1. an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) 2. the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Appears in 1 contract
Samples: Double Taxation Agreement
Associated Enterprises. Where -
(a) an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other StateContracting States, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits income which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits income of that enterprise and taxed accordingly.
Appears in 1 contract
Samples: Double Taxation Agreement
Associated Enterprises. Where -
(a) an enterprise of one of the States a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the States a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise enterprises and taxed accordingly.
Appears in 1 contract