Associated enterprise definition expands control, ownership and dependency tests to capture related parties in tax. The clause defines associated enterprise by reference to participation in management, control or capital, directly, indirectly or through intermediaries, ... Summary
Associated enterprise definition expands control, ownership and dependency tests to capture related parties in tax.
The clause defines associated enterprise by reference to participation in management, control or capital, directly, indirectly or through intermediaries, and lists deeming criteria-cross holding and common ownership, dominant lending or guarantees, board appointment or common control, dependency on exclusive intangibles, supply or purchase influence, familial and partnership links, equity interest in firms, and other prescribed mutual interest relationships-that establish association; it also extends the concept to other units or persons in specified domestic transactions.
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