Abstract: The existence of different tax regimes and corporate rates of income tax between countries has given rise to international tax arbitrage and transfer pricing1 schemes. The objective of these schemes has been to minimize income tax expense and tax liabilities of Multinational2 Corporations (MNCs). This paper considers the activities undertaken by these MNCs and the issues presented by these activities. A high-level tax plan is outlined for the fictional; Multinational Technology Company called The Multinational Technology Company to consider in its quest to minimize the company’s consolidated effective income tax expense.