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of <h1>Government may notify jurisdictions as low information areas; transactions treated as international associated enterprises dealings, triggering transfer-pricing and withholding rules</h1> The Central Government may designate jurisdictions lacking effective information exchange as notified areas; transactions involving a person located there are treated as between associated enterprises and as international transactions, bringing transfer-pricing rules into play. Deductions for payments to financial institutions in such areas require a prescribed authorization to permit information requests; other deductions or allowances arising from such transactions require prescribed documentation. Unexplained receipts from persons in notified areas may be taxed as the recipient's income. Tax withholding on payments to such persons must apply at the highest of the applicable rate, the rate specified by law, or 30%. Definitions of 'person located,' 'permanent establishment' and 'transaction' are provided.
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