Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their ?? ax risk appetite?? on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) ?? arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time.