Under Article 9 of the UN and OECD Model Tax Conventions, two enterprises are related parties with respect to each other if (in general) one of them participates directly or indirectly in the management, control or capital of the other enterprise; or they are under common control.
Under Article 9 of the UN and OECD Model Tax Conventions, two enterprises are related parties with respect to each other if (in general) one of them participates directly or indirectly in the management, control or capital of the other enterprise; or they are under common control.