Section 163 - Meaning of international transaction.

International transaction: cross-border dealings between associated enterprises defined to include tangible, intangible, financing, services and deemed arrangements.

An international transaction means a transaction between associated enterprises where at least one is a non-resident, encompassing tangible and intangible property transfers or use, capital financing and debt, provision of services, business restructuring, cost allocation arrangements, and any other transaction affecting profits, income, losses or assets. Transactions with non-associated persons may be deemed international where a prior agreement exists with an associated enterprise or where transaction terms are, in substance, determined with an associated enterprise. Intangible property is defined broadly to include marketing, technology, artistic, data processing, engineering, customer, contract, human capital, location, goodwill related intangibles and other items deriving value from intellectual content.