Associated Enterprises

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....trol or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, (a) 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 ....

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....due regard shall be had to the other provisions of this Agreement and the competent authorities of the Contracting States shall, if necessary, consult each other.] The following paragraph 1 of Article 17 of the MLI applies and supersedes the provisions of this Agreement: ARTICLE 17 OF THE MLI - CORRESPONDING ADJUSTMENTS Where a [Contracting State] includes in the profits of an enterprise ....