The document discusses three transfer pricing case studies:
1) Glaxo-Smithkline between US and UK - GSK was charged with undervaluing R&D costs in the UK and overvaluing marketing costs in the US to avoid taxes.
2) Compaq Computer between US and Singapore - Compaq justified transfer prices using cost-plus pricing which the IRS eventually accepted.
3) Seagate Technology between US and Singapore - The IRS claimed royalty payments between subsidiaries were too low but Seagate was unable to fully convince them.