09.03.2014 Views

Mr. Colin Clavey, World Bank/IFC - International Tax Dialogue

Mr. Colin Clavey, World Bank/IFC - International Tax Dialogue

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How to define associated enterprises?<br />

• Enterprises are associated where one<br />

controls the other, or they are under<br />

common control.<br />

• How define control?<br />

• Dangers in defining too widely?<br />

“Sum of loans provided to the enterprise is greater than 50%<br />

assets”<br />

“Value of sales to, or purchases from, the enterprise is greater<br />

than 50% of turnover”<br />

.. Or too narrowly?

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