International transactions under the new tax law broaden scope and require arm's-length pricing, expanded documentation, and deemed-transaction rules.
The Income Tax Act, 2025 redefines international transaction under section 163 to require dealings between associated enterprises with at least one non-resident and enumerates tangible and intangible property, services, capital financing, cost-sharing arrangements, business restructurings, and a residual clause. It introduces deemed international transactions to capture indirect arrangements determined by associated enterprises, expands the statutory definition of intangible property to include modern digital and contractual rights, and increases documentation and compliance obligations to align with OECD/BEPS guidance and prevent profit shifting. (AI Summary)

Crypto asset reporting requires providers to collect user identity, tax residency, and transaction data for automated tax exchange.
Under the CARF, crypto-asset service providers must perform customer due diligence, capture identity details, tax residency, and full transaction histories including gains and losses, and report this standardized information to competent authorities for automatic exchange; UK rules require reporting 2026 activity by May 31, 2027, and impose fines, interest, account suspension, and enhanced penalties for inaccurate information or unpaid tax. (AI Summary)