My advice would be to copy the complete folders from your OneNote Notebooks folder. Most of the time you will find this folder in your documents folder. For instance if you have a notebook about Holidays you would have a Holdidays folder in your OneNote notebooks folder. Copy the complete Holidays folder from your windows 7 pc to your Windows 8 pc. Place it in the documents folder in your OneNote notbooks folder. Then open OneNote and from OneNote browse to the directory containing your Holidays book. From that directory open the .onenote toc file. That should open your Notebook with all the sections in their proper place. Good subject. I will write a blogpost on that.

Visit my blog for other tips: the onenote corner ( http://theonenotecorner.wordpress.com/ )

Thanks for the tip, but that approach makes it very laborious as I have over 50 "notebooks: within OneNote.
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What I discovered is that you move the entire "Notebooks" folder to my new (8.1) machine to start with. It goes into the Documents folder, i.e., the same location on the Win 8.1 machine as it was on the old Win 7 SP1 machine.

Then I used the following process that works for me - this does not guarantee that it will work for everyone, but it is a start.

Open the application regedit.exe on the Win 7 machine and find the following key -
HKEY_CURRENT_USER/Software/Microsoft/Office/14.0/OneNote/OpenNotebooks

Export this key to a file on a flash drive. You will be asked to specify a file name and a folder for the file. Give the file the same name as it had on the Win 7 machine - OpenNotebooks. The .reg suffix will be attached automatically by the Export operation. You can actually export it directly to the flash drive.

Move the flash drive from the old Win 7 machine to the new Win 8.1P machine.

Using Windows Explorer, find the file that you exported to the flash drive.

Double click on it and Windows will place the new file in the appropriate Registry location.

You should now be able to open One Note and all the old folders and pages should be there.
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That is what worked for me.

WesternGuy