Article 9 - Associated Enterprises

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..... 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 financial relations which differ from those which would be made between independent enterprises, then any profits which wo .....

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..... its. In determining such adjustment, due regard shall be had to the other provisions of this Convention and the competent authorities of the Contracting States shall if necessary consult each other. [ Para 2 of Article 9 ] As per UN Model Tax Convention Article 9 of the United Nations Model Convention reproduces Article 9 of the OECD Model Convention. except of the .....

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