https://www.taxtmi.com/acts?id=37376 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. en-us Tue, 20 Aug 2019 16:32:58 +0530 Mon, 10 Feb 2025 17:11:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37376 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. Act-Rules DTAA Tue, 20 Aug 2019 16:32:58 +0530 https://www.taxtmi.com/acts?id=37376