Associated enterprise profit adjustments: where intercompany conditions deviate from independent dealings, profits may be reallocated and taxed. Where one enterprise directly or indirectly participates in the management, control or capital of an enterprise of the other territory, or common persons participate in both, and conditions between the enterprises differ from those between independent enterprises, any profits which but for those conditions would have accrued may be included in the profits of that 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 enterprise profit adjustments: where intercompany conditions deviate from independent dealings, profits may be reallocated and taxed.
Where one enterprise directly or indirectly participates in the management, control or capital of an enterprise of the other territory, or common persons participate in both, and conditions between the enterprises differ from those between independent enterprises, any profits which but for those conditions would have accrued may be included in the profits of that enterprise and taxed accordingly.
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