(a)two companies (“A” and “B”) are party to any arrangements (whether or not at the same time),
(b)A and B are members of the same group,
(c)the arrangements result in what is, in substance, a payment (directly or indirectly) from A to B of all or a significant part of the profits of the business of A or of a company which is a member of the same group as A or B (or both) (“the profit transfer”), and
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