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1. Multi-jurisdictional Considerations: Required when the ATPA involves multiple tax jurisdictions or potential impact on other countries' tax treatment

2. Group Structure Overview: Needed for complex corporate structures to clarify relationships between related entities

3. Dispute Resolution Procedures: Additional procedures for resolving disagreements, particularly relevant for bilateral or multilateral ATPAs

4. Force Majeure: Provisions for extraordinary circumstances that might affect the application of the agreed methodology

5. Language: Required when multiple official versions of the agreement exist in different languages

6. Competent Authority Proceedings: Needed when the agreement might interact with competent authority procedures or mutual agreement procedures

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

2. Schedule B - Transfer Pricing Methodology Details: Comprehensive explanation of calculation methods, including formulas and examples

3. Schedule C - Financial Projections: Expected financial outcomes and ranges under the agreed methodology

4. Schedule D - Critical Assumptions Detail: Detailed explanation of each critical assumption and its parameters

5. Schedule E - Functional Analysis: Detailed analysis of functions performed, risks assumed, and assets used by each party

6. Schedule F - Comparability Analysis: Documentation of comparable transactions or companies used in the analysis

7. Appendix 1 - Supporting Documentation: List of all supporting documents provided during the ATPA application process

8. Appendix 2 - Compliance Template: Template for annual compliance reporting

9. Appendix 3 - Organization Charts: Relevant corporate structure diagrams and operational flowcharts