APA作为调整跨国公司转移定价的新制度体现了税收效率原则,但也不是十全十美的。APA的发展依赖着传统转移定价调整方法的完善,其自身也要在主体、时效、国际性上不断改进,更重要的是为了促进APA的发展,是否应当披露APA协议的内容成为当前争议的热点,这对于APA制度还处于起步阶段的我国来讲是值得关注的。 APA as a new system to adjust the transfer pricing of multinational corporations reflects the principle of tax efficiency, but it is not perfect. The development of APA relies on the perfection of the traditional transfer pricing adjustment method. It must also improve itself in terms of subject, aging and internationalization. More importantly, in order to promote the development of APA, whether to disclose the content of the APA agreement becomes a hot topic in the current dispute , Which is noteworthy for our country where the APA system is still in its infancy.