Advance Pricing Agreement provides a voluntary mechanism to fix arm's length pricing and deliver tax certainty in international transactions. Advance Pricing Agreements permit the tax administration, with governmental approval, to enter into binding arrangements with taxpayers that fix the arm's length price or prescribe the method for its determination for specified international transactions between associated enterprises. The APA process is voluntary and supplements appeals and Double Taxation Avoidance Agreement mechanisms to provide tax certainty, with procedural modalities set out in an implementing APA scheme of tax rules.