If it is found that two or more persons are in association as a result of their economic, financial and organizational practices in the business in accordance with Clause (2) of Article 9 of this Resolution, and such persons are not registered as a tax group and artificially segregate their business, the value of the taxable supplies of each person shall be aggregated to determine whether they both have exceeded the Mandatory Registration Threshold and Voluntary Registration Threshold.

If the business is not segregated artificially but the Authority finds that there is a shortfall in tax revenues as a result of the segregation of such business, the Authority may aggregate the taxable supplies of each of the persons to determine whether the total taxable supplies have exceeded the Mandatory Registration Threshold and Voluntary Registration Threshold.

If any of the cases set forth in Clause (1) or (2) of this Article occurs, each of the persons shall be treated as making taxable supplies made by the other related parties and shall apply for tax registration if the Mandatory Registration Threshold is exceeded in accordance with the provisions of the Decree-Law.