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16.—(1) The provisions of paragraph (2) are by way of supplementation of the provisions of section 127 of the Taxes Act.
(2) Where, in the case of any payment, value transferred or profits or gains to which Schedule 11 or these Regulations apply, it is necessary, in order to arrive at the appropriate amount of such payment, value or profits or gains for any tax year or other period, to make any apportionment, division or aggregation of any amounts or values, any such apportionment, division or aggregation, shall be made as is just and reasonable.
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