Executive Rule No. 49 addresses the tax treatment of legally or financially associated companies to prevent tax avoidance. It empowers the Tax Department to inspect inter-company transactions, ensuring they are conducted on sound bases comparable to those between unrelated entities. The Rule provides definitions for Holding, Subsidiary, Branch, and Associate companies. It mandates that each Incorporated Body is treated as an independent legal entity for tax computation, prohibiting the integration of activities. Special and exceptional cases must be handled separately after direct consultation with the Tax Department.
Executive Rule No. 49 Concerning the tax treatment of related companies
These are companies, which are legally or financially associated, thus creating common interests. This relation affects the tax law compliance whether by dividing the tax burden among them or by tax avoidance, evasion or reduction thereof.
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