TMI BlogAssociated enterprisesX X X X Extracts X X X X X X X X Extracts X X X X ..... agement, 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 a Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e not so accrued, may be included in the profits of that enterprise and taxed accordingly.
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