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July 17, 2026
Article 132 provides the legal definition of 'Control' for tax purposes. A person controls a company if they have the direct or indirect right to manage its business and commercial affairs. Specific triggers include: (1) holding the majority of capital, issued shares, or voting rights; (2) holding rights that entitle them to the majority of distributed income; or (3) holding rights to the majority of assets upon the company's dissolution. Future rights or interests are treated as currently held for this determination. This rigorous definition is essential for applying related-party and anti-avoidance rules throughout the Law.
Article 132
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