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1. Critical Assumptions: Specific assumptions underlying the transfer pricing methodology, used when there are particular market or operational conditions that could affect pricing

2. Advance Pricing Arrangement (APA) References: Required when the agreement is part of or related to an APA with tax authorities

3. Force Majeure: Provisions for extraordinary circumstances affecting pricing, included when operating in volatile markets or high-risk jurisdictions

4. Dispute Resolution: Detailed dispute resolution procedures, recommended when parties are in different jurisdictions

5. Intellectual Property Rights: Required when the transfer pricing involves intangible assets or IP rights

6. Cost Sharing Provisions: Included when parties share development costs or other significant expenses

7. Currency and Exchange Rate Provisions: Required for cross-border transactions involving multiple currencies

8. Compensating Adjustments: Procedures for year-end adjustments, included when significant price variations are expected

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

2. Schedule B - Pricing Methodology Details: Technical details of pricing calculations, including formulas and examples

3. Schedule C - Functional Analysis: Analysis of functions performed, risks assumed, and assets employed by each party

4. Schedule D - Benchmarking Study: Comparable company analysis and market data supporting the chosen transfer pricing method

5. Schedule E - Documentation Requirements: Specific documentation templates and requirements for Austrian compliance

6. Appendix 1 - Financial Metrics: Key financial indicators and targets used in pricing calculations

7. Appendix 2 - Reporting Templates: Standard templates for periodic transfer pricing reports and adjustments

8. Appendix 3 - Contact Details: List of key contacts and responsible persons for each party