Under Section 482 of the U.S. Internal Revenue Code, the pricing of intercompany transactions must be at an arm's-length basis.

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Section 482 of the U.S. Internal Revenue Code requires that the pricing of transactions between related entities (intercompany transactions) be consistent with the prices that would be charged between unrelated parties under similar circumstances, ensuring they meet the arm's-length standard. This is to prevent tax evasion through the manipulation of transfer pricing.