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Arm's length price

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Arm's length price
The price at which a willing buyer and a willing unrelated seller would freely agree to transact or a trade between related parties that is conducted as if they were unrelated, so that there is no conflict of interest in the transaction.

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Again, the use of a per se list is consistent with the OECD guidelines, which provide that in some circumstances, "the additional tax revenue that would be collected does not justify the costs and administrative burdens of determining what an appropriate arm's length price might be in some cases.
The proposed regulations provide guidance on the transfer pricing methods to be used to determine the arm's length price in a services transaction.
Acceptable methods for determining arm's length prices are detailed within the Sec.
 
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