Determination of income from international transaction having regard to arm's length price.

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..... determined having regard to the arm's length price. (2) The allocation or apportionment of, or any contribution to, any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided to any associated enterprise shall be determined having regard to the arm's length price of such benefit, service or facility, as the case may be, if— (a) two .....

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