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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 9

Associated Enterprises

(1) Where:

  • (a) an enterprise in a Contracting state, directly or indirectly, contributes in the management, control or capital of an enterprise in the other Contracting state; or
  • (b) the same persons, directly or indirectly, contribute in the management, control or capital of an enterprise in a Contracting state and an enterprise in the other Contracting state.

(2) In both cases, if conditions were set between the two enterprises regulating their commercial or financial relations and they are different from those which might be expected to regulate the relations between independent enterprises, then any profits prevented due to such conditions may be included in the profits of that enterprise and taxed accordingly.