Associated enterprises rule allows allocation of profits where intercompany conditions differ, enabling taxation on arm's-length basis. Where enterprises are related through participation in management, control or capital, and conditions between them differ from those between independent enterprises, profits that would otherwise have accrued but did not due to those conditions may be included in the profits of the enterprise and taxed accordingly to reflect arm's-length outcomes.
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 allows allocation of profits where intercompany conditions differ, enabling taxation on arm's-length basis.
Where enterprises are related through participation in management, control or capital, and conditions between them differ from those between independent enterprises, profits that would otherwise have accrued but did not due to those conditions may be included in the profits of the enterprise and taxed accordingly to reflect arm's-length outcomes.
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