Transfer Pricing Taxation is a system that taxation is considered as if a transaction had been made at the arm’s length price when its transfer price is different from the transaction price at which a third party, not a group company, is willing to pay (referred to as the "arm's length price").

Depending on the setting of transfer pricing, the distribution of profits within a group of companies change and the amount of tax payments in the respective countries will change.

If the profits in one country are increased, the profits in the other country are reduced. Consequently, the scramble of the national interest on those profits has intensified. In addition, as the globalization of the economy proceeds and international trade by multinational companies will be getting more complicated,  setting an appropriate transfer price will not be straightforward.