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of <h1>Multinational Companies Must Align Cross-Border Transactions with Fair Market Pricing to Prevent Artificial Profit Shifting</h1> The statutory provision addresses associated enterprises in international taxation, focusing on transfer pricing and arm's length principles. When related enterprises engage in commercial or financial relations under conditions different from independent enterprises, tax authorities can reallocate profits. The provision allows for tax adjustments if profits would have been different under market-standard conditions, with safeguards against penalties for fraud or gross negligence. The aim is to prevent tax avoidance through manipulated inter-enterprise transactions.
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