Transfer pricing scope: defines international transactions and intangibles, and treats certain dealings with unrelated parties as associated.

Defines international transaction as dealings between associated enterprises involving tangible or intangible property, capital financing, services, or business restructuring, and includes cost-allocation arrangements. Transfer pricing applies to two non-resident associated enterprises only where income of one non-resident is assessable domestically. Intangible property is broadly defined to include marketing, technology, artistic, data-processing, engineering, customer, contract, human capital, location, goodwill related items, and any item deriving value from intellectual content. A transaction with an unrelated person is deemed international if a prior agreement exists with an associated enterprise or if its terms are determined with an associated enterprise.

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