Associated enterprises principle permits allocation of unrealised profits for tax purposes where intercompany conditions deviate from arm's length. Where associated enterprises impose or agree to conditions in their commercial or financial relations that differ from those which would have been made between independent enterprises, any profits which would have accrued but for those conditions may be included in the profits of the 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 principle permits allocation of unrealised profits for tax purposes where intercompany conditions deviate from arm's length.
Where associated enterprises impose or agree to conditions in their commercial or financial relations that differ from those which would have been made between independent enterprises, any profits which would have accrued but for those conditions may be included in the profits of the enterprise and taxed accordingly.
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