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of <h1>Article 10 of DTAA: Tax Rules for Enterprises with Shared Management or Control Across Contracting States</h1> Article 10 of the Double Tax Avoidance Agreement (DTAA) between France and another Contracting State addresses associated enterprises. It applies when an enterprise in one state participates in the management, control, or capital of an enterprise in the other state, or when the same individuals manage, control, or hold capital in enterprises of both states. If conditions between these enterprises differ from those between independent enterprises, profits that would have accrued to one but did not due to these conditions may be included in that enterprise's profits and taxed accordingly.
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