Economic globalization impacts to the increase of International transactions. The Company does not boundary their operation within their county anymore, but also extends their business performance abroad and may become multinasional and transnational typed of enterprise. The company then will be operating through its affiliates and branchs in many countries. This brings a consequence of a transfer pricing arrangement in their inter-group transactions. Transfer pricing could be conducted among others with taxes motivation, in which the main objective is to transfer the tax burden from the higher rated country to the lower rate jurisdiction. Under this circumstance, some countries may have losses the potential taxes revenue because of such transfer mechanism. To anticipate the conditions outlined above, Indonesian Tax Law introduces a transfer pricing resolution so called Advance Pricing Agreements (APA). APA are short of agreement betwen the tax authority and the tax payers on the reasonable (fair) selling prices of the product that has been concluded to the parties who has special relationship to justify that the transactions are arms length.