This paper discusses from the following four aspects: Firstly, about the quality of the procuratory power.

Bilateral Advance Pricing Arrangement(BAPA) is a kind of cooperation of tax collection based on modest restraint of power to tax by the tax authorities of two countries,which aims at the solution of tax avoidance problem of transfer pricing of multinational company and effective avoidance of double taxation.

The theory of material benefits for bribe should be persisted,because of the modest character of criminal law and the different treatment in criminal policy.