According to IRS code Section 482,what is the standard used by the IRS for international transfer pricing?

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The standard used by the IRS for international transfer pricing is "arm's length prices", which means that the prices charged in a transaction between related parties should be similar to the prices that would be charged in a comparable transaction between unrelated parties. This ensures that related parties are not manipulating prices to shift profits between different tax jurisdictions. Cost-based prices, discretionary prices, and negotiated prices are not the standard used by the IRS.

According to IRS Code Section 482,what Is the Standard Used