Associated Enterprises

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..... 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, by reason of those conditio .....

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..... e Contracting States shall if necessary consult each other. ] **************** NOTES:- 1 . Substituted vide Notification No. 47/2014 dated 24-09-2014 before it was read as, ARTICLE 10 ASSOCIATED ENTERPRISES Where: (a) an enterprise of 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 person .....

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