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of <h1>Transfer Pricing: Broad Definition of 'International Transaction' Includes Associated Enterprise Deals, Non-resident Influence, Intangibles, Financing, Services, Restructuring</h1> For purposes of transfer pricing, an 'international transaction' is any transaction between associated enterprises where at least one party is a non-resident, including dealings in tangible or intangible property, capital financing, lending or securities transactions, provision of services, reorganisation or restructuring transactions, cost-sharing or allocation arrangements, and any other transaction affecting profits, income, losses or assets. A domestic transaction with a third party is treated as international if its terms reflect a prior agreement with, or are substantially determined by, an associated enterprise and an enterprise or the associated enterprise is non-resident. 'Intangible property' is broadly defined and enumerated.
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