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1. Cost Sharing Provisions: Required when the agreement involves cost sharing arrangements between related entities

2. Intangible Property Provisions: Needed when the agreement covers transfers or licenses of intellectual property

3. Compensating Adjustments: Procedures for making adjustments when actual results fall outside agreed ranges

4. Dispute Resolution: Special procedures for resolving disagreements, needed for complex cases

5. Rollback Provisions: Include when applying the APA methodology to previous tax years

6. Force Majeure: Required when specific external events might impact the ability to apply the methodology

7. Currency and Exchange Rates: Needed when transactions involve multiple currencies

8. MAP Integration: Required when linking the APA to Mutual Agreement Procedure provisions

1. Schedule A - Covered Transactions: Detailed description of all intercompany transactions covered by the APA

2. Schedule B - Transfer Pricing Methodology Details: Technical details of the approved methodology, including formulas and calculations

3. Schedule C - Critical Assumptions Details: Comprehensive list and explanation of all critical assumptions

4. Schedule D - Annual Reporting Template: Format and content requirements for annual compliance reports

5. Appendix 1 - Financial Data: Historical financial data used to establish the transfer pricing methodology

6. Appendix 2 - Functional Analysis: Detailed analysis of functions, assets, and risks of involved entities

7. Appendix 3 - Comparables Analysis: Documentation of comparable companies or transactions used in the analysis

8. Appendix 4 - Organizational Structure: Corporate structure diagram and explanation of relevant relationships