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1. Multilateral Considerations: Required for bilateral or multilateral APAs involving multiple tax jurisdictions

2. Compensating Adjustments: Included when specific procedures for making transfer pricing adjustments need to be detailed

3. Dispute Resolution: Added when specific dispute resolution mechanisms beyond standard legal procedures are needed

4. Roll-back Provisions: Included when the APA methodology will be applied to previous tax years

5. Force Majeure: Added when specific provisions for extraordinary circumstances affecting the transfer pricing methodology are needed

6. Language: Required when the agreement needs to be valid in multiple languages

7. Competent Authority Procedures: Needed for bilateral/multilateral APAs to detail interaction with foreign tax authorities

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

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

3. Schedule C - Critical Assumptions Detail: Comprehensive explanation of critical assumptions and thresholds

4. Schedule D - Functional Analysis: Detailed analysis of functions, risks, and assets of involved entities

5. Schedule E - Financial Projections: Financial forecasts and budgets supporting the transfer pricing methodology

6. Appendix 1 - Compliance Report Template: Template for annual compliance reporting

7. Appendix 2 - Supporting Documentation: List of required supporting documentation for annual compliance

8. Appendix 3 - Organizational Structure: Detailed group structure and relevant related party relationships

9. Appendix 4 - Benchmark Analysis: Comparable company analysis and economic benchmarking studies