International transaction definition expanded to expressly include tangible and intangible transfers, services, financing and restructuring, widening transfer pricing scope. Amendment expands the scope of international transaction to include specified dealings between associated enterprises-tangible property transfers, use or lease; transfers or use of intangible property; capital financing and debt arrangements; provision of services; and business restructuring-and supplies a non exhaustive list of categories comprising intangible property, applying the clarification retrospectively to the earlier assessment period.
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Provisions expressly mentioned in the judgment/order text.
International transaction definition expanded to expressly include tangible and intangible transfers, services, financing and restructuring, widening transfer pricing scope.
Amendment expands the scope of international transaction to include specified dealings between associated enterprises-tangible property transfers, use or lease; transfers or use of intangible property; capital financing and debt arrangements; provision of services; and business restructuring-and supplies a non exhaustive list of categories comprising intangible property, applying the clarification retrospectively to the earlier assessment period.
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