Associated Enterprises

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..... 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 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, .....

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..... e competent authorities of the Contracting States shall if necessary consult each other in accordance with paragraph 2 of Article 25. 3. The provisions of paragraph 2 shall not apply in the case of fraud, gross negligence, or wilful default. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement .....

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