Rule 92 excludes from the safe harbour rules (86 to 91) eligible international transactions with an associated enterprise in a country or territory notified under section 176, or in a no tax or low tax country or territory.
92
Rules 2026 · Rule 92
Safe harbour rules for international transactions not to apply in certain cases
Rules 77-130
The rule. Rules 86, 87, 88, 89, 90 and 91 do not apply to eligible international transactions entered into with an associated enterprise located in any country or territory notified under section 176, or in a no tax or low tax country or territory.
Definition. A "no tax or low tax country or territory" is defined in rule 86 as one where the maximum rate of income-tax is less than 15%.