Article 9 - Associated Enterprises

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....irectly 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 would, but for those cond....

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.... 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 following paragraphs * The provisions of paragra....