Associated enterprises principle permits adjustment of profits where conditions deviate from arm's length and taxed accordingly. Article 10 applies where enterprises are associated by direct or indirect participation in management, control or capital, or by common participation, and where commercial or financial conditions between them differ from those between independent enterprises; in such cases profits that would have accrued but for those conditions may be included in the profits of an enterprise and taxed accordingly to restore an arm's length allocation.
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 adjustment of profits where conditions deviate from arm's length and taxed accordingly.
Article 10 applies where enterprises are associated by direct or indirect participation in management, control or capital, or by common participation, and where commercial or financial conditions between them differ from those between independent enterprises; in such cases profits that would have accrued but for those conditions may be included in the profits of an enterprise and taxed accordingly to restore an arm's length allocation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
