TMI BlogAssociated enterprisesX X X X Extracts X X X X X X X X Extracts X X X X ..... rise 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 income which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Contracting States shall if necessary consult each other. 3. A Contracting State shall not change the income of an enterprise in the circumstances referred to in paragraph 1 after the expiry of the time-limits provided in its national laws and, in any case, after five years from the end of the year in which the income which would be subject to such charge would, but for the conditions referr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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