Advance Pricing Agreement fixes arm's length pricing in advance and binds taxpayer and tax authorities for the agreed period. An Advance Pricing Agreement (APA) fixes the arm's length price (ALP) or the method of its determination for specified international transactions and, for the APA term, requires that ALP be determined solely under the APA. An APA is binding on the taxpayer and the Commissioner of Income Tax and subordinate authorities having jurisdiction. The regime contemplates multi year terms and includes statutory provisions that may render an APA nonbinding or void and regulatory provisions permitting revision or cancellation.