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of <h1>Arm's length pricing governs international and domestic transactions; allocations reflect arm's length; exception if adjustment reduces income or raises loss</h1> Any income from an international transaction, and allowances for related expenses or interest, must be computed with reference to the arm's length price. Where associated enterprises allocate, apportion or contribute to costs for benefits, services or facilities provided among them, such allocations must reflect arm's length pricing. The same principle applies to specified domestic transactions. These provisions do not apply if applying arm's length adjustments would reduce the income chargeable to tax or increase the loss as shown in the books for the year in which the transaction was entered into.
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