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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Jamaica: double taxation agreement, Article 6: Associated enterprises

Where-

  1. an enterprise of one of the territories participates directly or indirectly in the management, control or capital of an enterprise of the territory; or
  2. the same persons participate directly or indirectly in the management, control or capital of an enterprise of one of the territories and an enterprise of the other territory;

and in either case conditions are made or imposed between the two enterprises in theircommercial or financial relations which differ from those which would be made betweenindependent enterprises, then any profits which would, but for those conditions, haveaccrued to one of the enterprises, but, by reason of those conditions, have not so accruedmay be included in the profits of that enterprise and taxed accordingly.