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Peter Koerver Schmidt

to the same tests that apply to unrelated companies. With respect to the test of economic independence, the Commentary place emphasis on the number of principals represented by the agent, as independent status is less likely if the activities of the agent are performed wholly or almost wholly on behalf of only one enterprise over the lifetime of a business or a long period of time. Cf. Para. 38.6 OECD Model: Commentary on Article 5(6) (2014). On the one hand, it must be admitted that General Partner Foundation initially would only act as general partner with