Article 126

In determining the taxable income of a person who has entered into a transaction referred to in the foregoing Article 125, the effects of the transactions entered into under the conditions mutually agreed between the two persons shall be ignored if the terms agreed upon result in determination of a lower taxable income or higher loss allowable to be deducted or carried forward for that person than would be the case if it was between independent persons. Instead, the effects of such transactions shall be taken into account assuming the terms on which the transactions would have been entered into by independent persons.