Article 9 Associated enterprises

a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of the niche of the other Contracting State;

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 if in these cases, the two enterprises in their commercial or financial relations conditions that have agreed or imposed which differ from those that have been made between independent enterprises, then any profits which would, but for those conditions were accrued to one of the enterprises, but due to these conditions have not so accrued, may be included in the profits of the niche and taxed accordingly.