¶¶Òõ¶ÌÊÓƵ

1. Rollback Provisions: Optional section for applying the agreed methodology to previous tax years, used when there are open tax years that could benefit from the same treatment

2. Dispute Resolution: Additional procedures for resolving disagreements, included when specific dispute resolution mechanisms beyond standard administrative procedures are desired

3. Language: Section specifying the prevailing language version when multiple languages are used, needed in cases where the APA is prepared in multiple languages

4. Competent Authority Considerations: Added when there might be future needs to convert the unilateral APA to a bilateral one

5. Special Industry Considerations: Industry-specific provisions, included when the business operates in a highly regulated or specialized sector

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

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

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

4. Schedule D - Annual Reporting Template: Template and instructions for required annual compliance reports

5. Appendix 1 - Functional Analysis: Detailed analysis of functions, assets, and risks of the parties involved in the covered transactions

6. Appendix 2 - Economic Analysis: Supporting economic analysis and benchmarking studies

7. Appendix 3 - Organizational Structure: Relevant corporate structure diagrams and explanations

8. Appendix 4 - Financial Projections: Relevant financial forecasts and projections supporting the transfer pricing methodology