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Unilateral Advance Pricing Agreement

Unilateral Advance Pricing Agreement Template for Hong Kong

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Key Requirements PROMPT example:

Unilateral Advance Pricing Agreement

"Need a Unilateral Advance Pricing Agreement for our Hong Kong manufacturing subsidiary covering cross-border raw material purchases and finished goods sales with our mainland China parent company, to be effective from January 2025."

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Document background
A Unilateral Advance Pricing Agreement is a crucial tax planning tool for multinational enterprises operating in Hong Kong who seek certainty in their transfer pricing arrangements. This document type is particularly relevant when a company engages in significant related party transactions and wants to establish certainty regarding their transfer pricing methodology with the Hong Kong Inland Revenue Department. The agreement typically covers a 3-5 year period and includes detailed specifications of the approved pricing methodology, critical assumptions, and annual compliance requirements. It's especially valuable for companies with complex international transactions, helping them manage tax risks and avoid potential disputes with tax authorities. The document must comply with Hong Kong's transfer pricing legislation, including the Inland Revenue Ordinance (Cap. 112) and the guidance provided in DIPN 48.
Suggested Sections

1. Parties: Identifies the taxpayer and the Hong Kong Inland Revenue Department as parties to the agreement

2. Background: Explains the context of the APA request, including brief description of the business operations and transactions covered

3. Definitions: Defines key terms used in the agreement, including technical transfer pricing terms and specific business terminology

4. Scope of Agreement: Specifies the covered transactions, time period, and entities involved in the APA

5. Transfer Pricing Methodology: Details the agreed transfer pricing method(s), including calculation mechanisms and rationale

6. Critical Assumptions: Lists the fundamental assumptions upon which the APA is based

7. Term of Agreement: Specifies the duration of the APA and effective dates

8. Annual Compliance Requirements: Outlines the taxpayer's obligations for annual reporting and documentation

9. Revision and Cancellation: Conditions under which the APA may be revised or terminated

10. Confidentiality: Provisions regarding the confidential treatment of information

11. Governing Law: Confirms Hong Kong law as the governing law of the agreement

Optional Sections

1. Rollback Provisions: Used when the agreed methodology will be applied to previous tax years

2. Compensating Adjustments: Include when specific adjustment mechanisms are needed to meet agreed profit/price ranges

3. Dispute Resolution: Added for complex cases where specific dispute resolution procedures are necessary

4. Force Majeure: Include when specific provisions for extraordinary events affecting the APA are required

5. Multiple Transaction Types: Used when different methodologies apply to different categories of transactions

6. Renewal Provisions: Include when specific terms for APA renewal are agreed in advance

Suggested Schedules

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

2. Schedule 2: Transfer Pricing Calculations: Detailed formulae and examples of how the transfer pricing methodology will be applied

3. Schedule 3: Critical Assumptions Analysis: Detailed analysis and thresholds for critical assumptions

4. Appendix A: Financial Projections: Financial forecasts and budgets supporting the transfer pricing methodology

5. Appendix B: Functional Analysis: Detailed analysis of functions, assets, and risks of involved entities

6. Appendix C: Comparability Analysis: Details of comparable transactions or companies used in the analysis

7. Appendix D: Annual Compliance Report Template: Template for required annual compliance reporting

8. Appendix E: Supporting Documentation: List of all supporting documents referenced in the APA

Authors

Alex Denne

Head of Growth (Open Source Law) @ ¶¶Òõ¶ÌÊÓƵ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions







































Clauses





























Relevant Industries

Manufacturing

Technology

Financial Services

Pharmaceutical

Automotive

Consumer Goods

Professional Services

Telecommunications

E-commerce

Energy and Resources

Media and Entertainment

Logistics and Supply Chain

Relevant Teams

Tax

Finance

Legal

Treasury

International Tax

Transfer Pricing

Corporate Finance

Financial Planning & Analysis

Risk Management

Compliance

Relevant Roles

Tax Director

Chief Financial Officer

Transfer Pricing Manager

International Tax Manager

Head of Tax

Financial Controller

Tax Counsel

Global Tax Planning Director

Treasury Manager

Finance Director

Tax Compliance Manager

Corporate Controller

Group Financial Controller

Industries







Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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