Page 442 - ΔΟΚΙΜΗ

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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡfi\ΙΟΥ
1984
433
(2) For purposes of this Artiole, profits from the
operation
ίη
international traffic
ο! shi~s
or aircraft
inolude profits derived from the rental
οη
a full or bare–
boat basis
ο!
ships or aircraft
ί!
operated
ίη
internationa1
traffic by the 1essee or
ί!
such renta1 profits are incidenta1
to other profits described in paragraph (1).
(3)
Profits of a resident
ο! ~
Contracting State from
the use,
ιnalntenance οτ
rental
ο!
containers (i'ncluding
trai1ers, barges, and re1ated equipment for the transport
ο!
containers) used for the transport
ί,η
international
traffiσ
ο!
goods or merchandise sha11 be taxab1e only
ίη
that
Contracting State.
Article 11
RELATED PERSONS
(1) Where a person subject to the taxing jur.BdictioD
ο!
a
Contracting State and any other person are related and where
such related per80ns make arrangements or
impoβe
conditions
between themselves which are different from those which
would be made between independent persons,
any
income,
deductionβ,
credits, or a110wances which would, but for
those arrangements or conditions, have been taken illto
aocouηt ίη
computing the income (or 10SS) of, or the tax
payable by, one
ο!
such persons, may be taken into account
in computing the amount
ο!
the income
subjeσt
to tax and the
taxes payab1e by such person.
(2) For purposes
ο!
th1s Convention, a person 1s related
to another person
ί!
e1ther person
οννηΒ
or contro1s direct1y
or 1ndirectly the other,
οτ ί!
any
third person or persons
own
οτ
contro1 direct1y or 1ndirect1y both. For this purpose,
the
terιι:
"control" i.ncludes any k1nd
ο!
co.ntro1, whether or
llOt 1egal1y enforceable, and however
exercise~ οτ
exercisab1e.
(3)
Where an adjustment has been made by a Contracting
State in accordanoe w1th paragraph (1), the other Contracting
)
State sha11, 1! it agrees that the adjustment by the first-
ment10ned
Co.ntraσting
State was in aooordalloe with paragraph
(1), make a corresponding adjustment to the inaome,
1088
or
tax of the related person
that other Contracting State.