The importance of international transfer pricing (ITP) has increased alongside the globalisation of business and the increasing importance of international trade and global marketing. During the 1990s,the OECD and numerous different countries (including the United Kingdom and the United States) have published a series of transfer pricing guidelines, rules and regulations. These developments have raised the profile of ITP and increased teh pressures placed on multinational enterprises (MNEs) to ensure that their intra-group transactions reflect arm's length prices.