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Unformatted text preview: source if the two activities involve the design, manufacture or sale of the same products or types of products, or the provision of similar services. The line of business in the state of residence may be upstream, downstream, or parallel to the activity conducted in the state of source. Thus, the line of business may provide inputs for a manufacturing process that occurs in the state of source, may sell the output of that manufacturing process, or simply may sell the same sorts of products that are being sold by the trade or business carried on in the state of source. according to the technical explanation to the us model convention, for two activities to be considered complementary, it is unnecessary that they relate to the same types of products or services; they must, however, be part of the same overall industry and be related in the sense that the success or failure of one activity tends to result in the success or failure of the other. For example, an international airline company and a chain of hotels that are located near airports served by this comp...
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