In modern-day commercial enterprises, complex inter-relationships between sub-units are commonplace. Many of these relationships are subjected to or reflected by transfer prices that traditionally contribute to the economic co-ordination or optimisation and performance measurement of the affiliated sub-units. When trades cross national boundaries, there is also an opportunity for multinational enterprises to optimise global after-tax profit. From the mid 1990s, however, fiscal regulators have strengthened requirements to the extent that transfer pricing tax compliance becomes a potential alternative strategy. A review of the regulatory framework raises questions for the existing theory and practice not least in terms of the implications of adopting a tax-compliant strategy on the design of management control systems.