International transaction definition broadened: third-party dealings treated as international transactions when an enterprise or associated enterprise is non-resident.

The amendment expands the deeming rule in section 92B so that a transaction between an enterprise and an unrelated third party will be treated as an international transaction where the enterprise or the associated enterprise or both are non-residents, irrespective of the residential status of the third party, thereby subjecting such transactions to transfer pricing rules when terms are determined in substance by an associated enterprise.

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