4.5 Consolidated Tax Return

1. Affiliated Group

1) Affiliated group defined

More than 80% of the combined voting power of all outstanding stock AND 80% of the total value of all outstanding stock

2) Controlled group defined

(1) Parent-Subsidiary: 80% of combined voting power OR total value of stock

(2) Brother-Sister

(3) Combined

2. Consolidated Tax Returns

1) Intercompany Dividends

2) Advantage of filing consolidated return

3) Disadvantages of filing consolidated return

3. Transfer Pricing Taxation