Associated enterprises: when controlled relations deviate from independent terms, tax authorities may include adjusted profits in taxable income. Article 9 targets Associated Enterprises where direct or indirect participation in management, control or capital, or common persons, leads to commercial or financial conditions differing from those between independent enterprises; profits that would have accrued but for those conditions may be included in the enterprise's taxable profits 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: when controlled relations deviate from independent terms, tax authorities may include adjusted profits in taxable income.
Article 9 targets Associated Enterprises where direct or indirect participation in management, control or capital, or common persons, leads to commercial or financial conditions differing from those between independent enterprises; profits that would have accrued but for those conditions may be included in the enterprise's taxable profits and taxed accordingly.
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