International Transaction - Section 92B

International Transaction rules: cross-border dealings between associated enterprises treated as transfer pricing events subject to arm's length principles.

International transactions are dealings between associated enterprises covering tangible and intangible property, capital financing, services and business restructuring; they include cost-allocation agreements. Transfer pricing applies when at least one non-resident's income is assessable domestically if both parties are non-residents. Intangible property is broadly defined to include marketing, technology, artistic, data-processing, engineering, customer, contract, human-capital, location, goodwill-related assets and items deriving value from intellectual content. Transactions with unrelated persons are deemed international transactions where a prior agreement exists with an associated enterprise or where terms are determined by that associated enterprise.