Common use of Associated Enterprises Clause in Contracts

Associated Enterprises. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or b) the same persons participate directly 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, but for those conditions would have accrued to one of the enterprises, but by reason of those conditions have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions exist, or are made or imposed imposed, between the two enterprises in their commercial or financial relations which differ from those which would might be expected to exist or be made between independent enterprisesenterprises dealing wholly independently with one another, then any profits which, but for those conditions would conditions, might have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and 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, which would. but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions; have not so accrued, may be included in the profits of that enterprise enterprises and taxed taxes accordingly.

Associated Enterprises. (a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a one of the Contracting State States and an enterprise of the other Contracting State, and in either case conditions are made or imposed operate between the two enterprises in their commercial or financial relations which differ from those which would might be made expected to operate between independent enterprisesenterprises dealing wholly independently with one another, then any profits which, but for those conditions would conditions, might have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where (a) an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or (b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State one of the States 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. a) Where a. an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or b) b. the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State one of the States 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or (b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where— (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or (b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. If a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or; b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and if in either case conditions are made or imposed between these cases, the two enterprises in their commercial or financial relations conditions that have agreed or imposed which differ from those which would be that have been made between independent enterprises, then any profits which, but for those conditions would conditions, have accrued to one of the enterprises, but by reason of those due to these conditions have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. (a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a one of the Contracting State States and an enterprise of the other Contracting State, and in either case conditions are made or imposed operate between the two 2 enterprises in their commercial or financial relations which differ from those which would might be made expected to operate between independent enterprisesenterprises dealing wholly independently with one another, then any profits which, but for those conditions would conditions, might have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. a) Where - a. an enterprise of a Contracting State one of the territories participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; territory, or b) b. the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State one of the territories and an enterprise of the other Contracting Stateterritory, and and c. in either case conditions are made or imposed between the two enterprises enterprises, in their commercial or financial relations relations, which differ from those which would be made between independent enterprises, then any profits which, which would but for those conditions would have accrued to one of the enterprises, enterprises but by reason of those conditions have not so accrued, accrued may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other a Contracting State; , or (b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprisesenterprise, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; State or b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where: a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but by reason of those conditions conditions, have not so accrued, may be included by a Contracting State in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where: (a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the managementthemanagement, control, control or capital of an enterprise of a one of the Contracting State States and an enterprise of the other Contracting State, and in either case conditions are made or imposed operate between the two enterprises in their commercial or financial relations which differ from those which would might be made expected to operate between independent enterprisesenterprises dealing wholly independently with one another, then any profits which, but for those conditions would conditions, might have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. 1 Where: (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the management, control, 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 operate between the two enterprises in their commercial or financial relations which differ from those which would might be made expected to operate between independent enterprisesenterprises dealing wholly independently with one another, then any profits whichwhich might, but for those conditions would conditions, have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where (a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a one of the Contracting State States and an enterprise of the other Contracting State, and in either case conditions are made or imposed operate between the two enterprises in their commercial or financial relations which differ from those which would might be made expected to operate between independent enterprisesenterprises dealing wholly independently with one another, then any profits which, but for those conditions would conditions, might have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. (a) an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or (b) the same persons participate directly or indirectly in the management, control, control or capital of an enterprise of a Contracting State one of the States 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. a) Where: a. an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or b) b. the same persons participate directly or indirectly in the management, control, 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 enterprisesenterprise, then any profits which, which would but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. It is to be understood that the procedures available in the respective laws of each Contracting State in this regard shall be applied.

Associated Enterprises. a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or b) the same persons participate directly or indirectly in the management, control, 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 enterprise in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the management, control, 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 enterprise in their commercial or financial relations which differ from those which would be made between independent enterprisesenterprise, then any profits whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or (b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. Where a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; , or b) the same persons participate directly or indirectly in the management, control, 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 whichwhich would, but for those conditions would conditions, have accrued to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Associated Enterprises. 1 Where: (a) an enterprise of a Contracting State one of the Contrasting States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State; or (b) the same persons participate directly or indirectly in the management, control, or control of capital of an enterprise of a one of the Contracting State States and an enterprise of the other Contracting State, and in either case conditions are made or imposed operate between the two enterprises in their commercial or financial relations which differ from those which would might be made expected to operate between independent enterprisesenterprises dealing wholly independently with one another, then any profits which, but for those conditions would conditions, might have accrued been expected to accrue to one of the enterprises, but but, by reason of those conditions conditions, have not so accrued, may be included in the profits of that the enterprise and taxed accordingly.