Where a) an enterprise of a Contracting State participates directly or indi- rectly in the management, control or capital of an enterprise of the other Contracting State, or
Where a) an enterprise of a Contracting State derives an item of income from the other Contracting State and the first-mentioned State treats such item of income as attributable to a permanent establishment of the enterprise situated in a third jurisdiction; and
Where a) an enterprise of one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other State, or
Where a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and