Arm's length price required for international transactions, determining income, expenses and intercompany cost allocations. Income from an international transaction must be computed with regard to the arm's length price, and allowances for expenses or interest in such transactions are similarly determined. Cost allocations, apportionments or contributions among associated enterprises for benefits, services or facilities must be measured by the arm's length price. These provisions do not apply if their operation would reduce taxable income or increase loss relative to the books of account for the previous year in which the international transaction occurred.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price required for international transactions, determining income, expenses and intercompany cost allocations.
Income from an international transaction must be computed with regard to the arm's length price, and allowances for expenses or interest in such transactions are similarly determined. Cost allocations, apportionments or contributions among associated enterprises for benefits, services or facilities must be measured by the arm's length price. These provisions do not apply if their operation would reduce taxable income or increase loss relative to the books of account for the previous year in which the international transaction occurred.
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