Nigeria introduced Transfer Pricing Regulations in August 2012. One of the innovations of the Regulations is the introduction of Advance Pricing Agreements (APAs). This discourse would, inter alia, examine what an APA is, the types of APAs, their relevance to both taxpayers and tax administrations, the provisions of the Nigerian Transfer Pricing Regulations relating to APAs and recommendations for best practices. However, before discussing APA, it would be necessary to succinctly define ‘transfer pricing’. So, what then is ‘transfer pricing’?