Cabinet Decision No. 39 of 2019, Article 64, provides the legal basis for Advance Pricing Agreements (APAs). It empowers the Minister to issue detailed regulations outlining the conditions and procedures for bilateral APAs. These agreements allow taxpayers to agree on transfer pricing methodologies with the Authority in advance, providing tax certainty for future transactions. This proactive approach helps businesses manage tax risks and avoid future disputes, provided they adhere to the agreed-upon controls and international transfer pricing standards specified by the Ministerial decision.