Associated enterprises rule permits profit adjustments where controlled relations deviate from independent enterprise terms, enabling taxation accordingly. Article 9 permits adjustment of profits where enterprises are connected by direct or indirect participation in management, control or capital, or by common persons, and where their commercial or financial conditions differ from those between independent enterprises; profits that would have accrued but for those conditions may be included in the taxable profits of the affected enterprise and taxed accordingly.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Associated enterprises rule permits profit adjustments where controlled relations deviate from independent enterprise terms, enabling taxation accordingly.
Article 9 permits adjustment of profits where enterprises are connected by direct or indirect participation in management, control or capital, or by common persons, and where their commercial or financial conditions differ from those between independent enterprises; profits that would have accrued but for those conditions may be included in the taxable profits of the affected enterprise and taxed accordingly.
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