Arm's length price requirement governs computation of income and cost allocations in related-party transactions. Income from an international transaction and allowances for related expenses or interest must be computed having regard to the arm's length price; ... Summary
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Arm's length price requirement governs computation of income and cost allocations in related-party transactions.
Income from an international transaction and allowances for related expenses or interest must be computed having regard to the arm's length price; allocations or contributions of costs among associated enterprises for benefits, services or facilities must likewise be determined by reference to the arm's length price, and these arm's length adjustments shall not be applied so as to reduce taxable income or increase loss compared with the books of account for the relevant previous year.
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