The profit and loss of a business of a TK operator under a TK agreement is attributed to a TK investor, by which a TK operator is able to substantially reduce the burden of corporate taxes, importantly, a TK investor is not entitled to have any control right over the business of TK operator This is an intrinsic restriction on a TK investor’s rights, and any violation could jeopardize treatment as a TK arrangement, although the court ruling is not clear.