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When an associated enterprise consistently realizes losses whilethe MNE group as a whole is profitable, the facts could trigger some specialscrutiny of transfer pricing issues. Of course, associated enterprises, likeindependent enterprises, can sustain genuine losses, whether due to heavystart-up costs, unfavourable economic conditions, inefficiencies, or otherlegitimate business reasons. However, an independent enterprise would notbe prepared to tolerate losses that continue indefinitely. An independententerprise that experiences recurring losses will eventually cease toundertake business on such terms. In contrast, an associated enterprise thatrealizes losses may remain in business if the business is beneficial to the MNE group as a whole.
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