Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 8
Joint Projects with Special Conditions
A contracting state may not consider the conditions pertinent to the commercial and financial relations between two or more projects if such conditions are likely to reduce the taxable profits in such state in the following two (2) cases:
- (a) if a project related to a contracting state contributes either directly or indirectly in the capital, management or control of a project that is related to the other contracting states.
- (b) or if the same persons participate either directly or indirectly in the capital, management or control of a project related to a contracting state and a project that is related to another contracting state.