In October 1996, after the implementation of NAFTA, the Secretariat of Commerce and Industrial Development ("SECOFI"), which reviews applications and grants permits for Maquiladoras, was given the power to deny or cancel existing permits if SECOFI determined that the Maquiladora's operations would have an adverse affect on the Mexican national non-Maquiladora industry.1 This was a protective measure to mitigate the effects of allowing Maquiladoras to sell their products within the domestic Mexican market. That same year, Maquiladora operations became subject to taxation on the value of assets imported into Mexico, or, as an alternative, compliance with Mexico's income tax law provisions on transfer pricing.2 The transfer pricing law allowed