The globalization, the international trade and the number of multinational enterprises have continued to increase over the last decade. Today over 70 percent of the cross-border transactions take place between related enterprises. The growth of multinational enterprises doing cross-boarder transactions present increasingly complex taxation issues, both for the tax authorities and the companies themselves. International transfer pricing deals with those intra-group transactions where the open market regulator is absent. Transfer pricing has grown to be the most important issue on the tax...