This article introduces a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective. Each contributor will deal with the more basic question how the relevant country in general focuses on transactions between its residents and residents of low-tax countries. The responses to this central issue provide the reference framework for the evaluation and assessment of the rules aimed at combating restructuring operations on the grounds of abuse of law or abuse of local transfer pricing rules. The different flavours in the range of measures intended to challenge adverse positions, are briefly considered.