Safe harbour eligibility for international transactions depends on valid option, low-risk functions, foreign principal control, and limited risk allocation.

Eligible assessee status for safe harbour rules applies only where a person has exercised a valid option under the safe harbour framework and falls within specified categories, including certain low-risk information technology services, intra-group loans, corporate guarantees, contract research and development relating to generic pharmaceutical drugs, manufacture and export of core or non-core auto components with predominant OEM sales, receipt of low value-adding intra-group services, or provision of data centre services to a foreign company. For low-risk information technology services and pharmaceutical contract research and development, the foreign principal must perform the economically significant functions, provide funds and intangibles, supervise the assessee, and retain the ownership of any intangible or research outcome.

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