Associated enterprises: divergent intercompany conditions permit inclusion of profits in taxable income and corresponding tax adjustment. Article 9 treats enterprises as associated where one participates directly or indirectly in the management, control or capital of the other, or where the same persons participate in both. If conditions between such enterprises differ from those between independent enterprises in their commercial or financial relations, profits that would have accrued but for those conditions may be included in the enterprise's 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: divergent intercompany conditions permit inclusion of profits in taxable income and corresponding tax adjustment.
Article 9 treats enterprises as associated where one participates directly or indirectly in the management, control or capital of the other, or where the same persons participate in both. If conditions between such enterprises differ from those between independent enterprises in their commercial or financial relations, profits that would have accrued but for those conditions may be included in the enterprise's profits and taxed accordingly.
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