67Under Article 143(1)(e) of Regulation No 2454/93, persons are to be deemed to be related if one of them directly or indirectly controls the other. The interpretative note on customs value concerning that provision, set out in Annex 23 to that regulation, states, in that regard, that one person is to be deemed to control another when the former is legally or operationally in a position to exercise restraint or direction over the latter.
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