The jurisdiction to tax focuses on who has the right to tax; inbound and outbound taxation focus on what to tax (passive or active income) and how to tax (withholding or tax return); and the transfer pricing legislation has the scope to determine how much to tax. This legislation, as well as Controlled Foreign Corporation (CFC), is addressed to those MNEs operating in more than one country through so-called “related companies”, being subsidiaries. The importance of transfer pricing has to do with the assumption that corporate income taxes (CITs) differ from country to country, and there might be a temptation for MNEs to make transactions with each other that do not reflect the real value of the goods and services being transferred.