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CHAPTER I - Income Tax
CHAPTER II - Registration Fees and Stamp Duties
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.


[Associated Enterprises]

(1) Where an enterprise of one of the Contracting States, due to its participation in the management or capital of an enterprise of the other Contracting State makes or imposes conditions on the latter, in their commercial or financial relations, which differ from those which would have been made with a third Party enterprise, then any profits which would otherwise appear in the accounts of one of the enterprises, but which thus have been transferred to the other enterprise, may be incorporated in taxable profits of the first mentioned enterprise.

(2) An enterprise is considered to participate in the management or capital of another enterprise especially when the same persons participate directly or indirectly in the management or capital of each of these two enterprises.