Arm's length pricing required for related party transactions, with a non application rule when it would reduce taxable income. Income, expense and interest arising from international or specified domestic transactions must be determined by reference to the arm's length price; allocations or contributions among associated enterprises for costs, expenses, benefits, services or facilities must reflect the arm's length price of those items; these provisions do not apply where applying them would reduce taxable income or increase a loss as reflected in the books for the tax year in which the transaction was entered.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arm's length pricing required for related party transactions, with a non application rule when it would reduce taxable income.
Income, expense and interest arising from international or specified domestic transactions must be determined by reference to the arm's length price; allocations or contributions among associated enterprises for costs, expenses, benefits, services or facilities must reflect the arm's length price of those items; these provisions do not apply where applying them would reduce taxable income or increase a loss as reflected in the books for the tax year in which the transaction was entered.
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