1029.8.36.127. For the purposes of this division, two or more corporations or partnerships operating an international financial centre are deemed to be members of an associated group, in a taxation year or fiscal period, or at the end of a taxation year or fiscal period, if it may reasonably be considered that one of the main reasons for the separate existence of those corporations or partnerships in that year or period, or at the end of that year or period, is to cause a corporation or a taxpayer, other than a tax-exempt taxpayer, who is a member of a partnership to be deemed to have paid an amount to the Minister under this division or to increase such an amount.