One of the overriding issues in international corporate income taxation is limiting the ability of firms to artificially (re)allocate profits to low or zero-tax jurisdictions to reduce their worldwide tax liability. Multinational enterprises (MNEs) can exploit differences in domestic tax laws to shift profits across borders and erode domestic tax bases using intra-group transactions, financial arrangements, and corporate structuring, which are unavailable to local companies. Specific avoidance activities include transfer pricing—for example, charging relatively lower prices for goods and services transferred from high-tax to low-tax affiliates—and the strategic use of inter-affiliate debt—for example, financing the activities of high-tax affiliates using debt issued by low-tax affiliates.