In a very basic sense, transfer pricing is a very important part of the work that all tax administrations have to do, because the economy is becoming global and taxpayers are working internationally all the time. As a result of that, when you have organizations and structures where an organization is either entering into a sales transaction or a transaction with one of its related companies offshore, what you find is that there are times when the companies are trying to take advantage of certain sales that should take place at fair market value that are being either undervalued or overvalued for a tax advantage.
So it's becoming, and is, a big issue. For example, at the OECD right now, Working Party No. 6 has an entire area devoted to transfer pricing to set out guidelines on an international level to make sure that all countries are working toward a solution for transfer pricing.