Where. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capi- tal 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 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 xxxxx- cial relations which differ from those which would be made between independent enterprises, then any prof- its which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those con- ditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
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Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capi- tal 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 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 xxxxx- finan- cial relations which differ from those which would be made between independent enterprises, then any prof- its which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those con- ditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
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Where. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capi- tal 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 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 xxxxx- finan- cial relations which differ from those which would be made between independent enterprises, then any prof- its which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those con- ditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
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Where. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capi- tal 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 a Contracting State and an enterprise of the other Contracting State, and in either case case, conditions are made or imposed between the two enterprises in their commercial or xxxxx- finan- cial relations which differ from those which would be made between independent enterprises, then any prof- its which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those con- ditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.accordingly.
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