When different subsidiaries of the same multinational corporation buy and sell goods and services between themselves at manipulated prices, with the intention of shifting profits into low-tax jurisdictions. Trades between subsidiaries of the same multinational corporation are supposed to take place ‘at arm’s length’, i.e. based on prices on the open market. Market prices can be difficult to quantify, however, particularly with respect to the sale of intangible assets such as services or intellectual property rights.