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of <h1>Section 162 widens 'associated enterprise' tests with bright-line thresholds, expanding transfer-pricing exposure and compliance burdens</h1> Section 162 defines 'associated enterprise' by combining a general participation test with specific deeming criteria (shareholding thresholds, loan/guarantee exposure, appointment control, IP/supply dependence, family/common control, minority interests and a residual 'mutual interest' clause). The Act consolidates indicia under one subsection while the Bill used a two-tier general/deeming structure; substance is largely unchanged aside from drafting, symmetry in appointment tests, and minor cross-reference differences affecting legacy incentive linkage. Objective thresholds create bright-line triggers for transfer-pricing/anti-avoidance rules and broaden exposure beyond shareholding, increasing recordkeeping and compliance risks for related transactions.
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