Seventeen sections on transfer pricing and the specific anti-avoidance rules that sit outside GAAR.
Sections 161 to 173 are the transfer pricing code: arm's length price, associated enterprise, international transaction, specified domestic transaction, the Transfer Pricing Officer, safe harbour rules, advance pricing agreements and secondary adjustment, with the documentation and accountant's report obligations in sections 171 and 172. Sections 174 to 177 then carry the older targeted rules — transfer of income to non-residents, transactions in securities, notified jurisdictional areas, and the limitation on interest deduction that practitioners know as thin capitalisation.