Control and beneficial ownership determine close relation; treaty permits parties to reserve exclusion of this definitional Article.

Definition establishes that a person is closely related to an enterprise where one controls the other or both are under common control, with control deemed to exist when one directly or indirectly holds more than half of the beneficial interest or, for a company, more than half of the aggregate voting power and value of shares or beneficial equity interest. Parties that have reserved specific anti avoidance provisions may extend those reservations to exclude this Article from applicable covered tax agreements.

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