>> Hello. And, welcome to module four of our course rethinking international tax law. In this module, we will be focusing on transfer pricing. This is a fascinating area of law, which is becoming increasingly important. As the OECD is progressing with its deliverables in the dev's project, classic tax planning opportunities resulting from mismatches between the tax systems from different countries will gradually disappear. And the same is true for opportunities to use or if you will abuse bilateral tax treaties to avoid withholding taxes on outgoing payments. What will be left from international companies is indeed transfer pricing. Transfer pricing is a technique which is used to allocate the profits made by a group of companies to the individual group members. Subsequently, the country in which the designated group member is resident may tax the profits of that company. You can imagine that this technique can be used by multinationals to shift profits from high tax jurisdictions to low tax countries. If we go back to our tax spending base case introducing module one,we will be talking about shifting profits from local activity or so,to Intermediate Sub 1 or from Intermediate Sub 1 to Intermediate Sub 2. It is therefore of great importance to study the subject of transfer pricing very closely. I'm very happy that my colleague and friend Dr. Stefano Simontacchi is taking you through the sometimes difficult area on the crossroads between law and economics. I wish you a great learning experience, and, above all, a lot of fun.