The Australian Taxation Office established the International Tax Division in 1993 to establish a better organizational focus on globalization. Multinational enterprises were managing an estimated 60 percent of world trade at that time; the bulk of these transactions were between related parties. Transfer pricing for prices supplied to related parties had not received extensive scrutiny for many years. The situation entailed all the risk factors for underpayment of tax. The International Tax Division determined that it needed to set clear objectives, develop an analytical approach, move from confrontation to cooperation, and use systemic approaches at the case level. The Division also recognized the need to develop a holistic picture of the multinational group and apply risk assessment and compliance monitoring at that level. In addition, it understood the needs to have a wider set of skills and to consider the whole framework of the law and its practical application. The agency’s experience underscores the importance of systemic approaches and the need to regard the tax system as a behavioral model involving many stakeholders, including taxpayers, their advisors, the judiciary, the government, other countries, the Australian Tax Office, and the wider community. Other lessons include the need to humanize the analysis and management of compliance, ensure that taxpayers feel that they have received fair handling, and operate in real time.