Australian Tax Treaties
Ad Articles 5 and 7
For the purposes of preventing misuse of Articles 5 and 7 , in determining the duration of activities under paragraphs 3 and 4 of Article 5 , the period during which activities are carried on in a Contracting State by an enterprise associated with another enterprise (other than enterprises of that Contacting State) may be aggregated with the period during which activities are carried on by the enterprise with which it is associated if the first-mentioned activities are connected with the activities carried on in that State by the last-mentioned enterprise, provided that any period during which two or more associated enterprises are carrying on concurrent activities is counted only once. An enterprise shall be deemed to be associated with another enterprise if one is controlled directly or indirectly by the other, or if both are controlled directly or indirectly by a third person or persons.
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