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May 15, 2026

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 55

To apply the arm's length principle, every linked entity must annually update the financial data for comparable transactions that occur between it and an independent entity or between two independent entities.

A linked entity must update its search for comparable transaction data in financial databases every three years, provided that its business conditions remain unchanged.