Unilateral Advance Pricing Agreement Template for Canada

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

2. Compensating Adjustments: Include when specific adjustment mechanisms are needed to achieve agreed pricing outcomes

3. Dispute Resolution: Added when specific dispute resolution procedures beyond standard administrative processes are required

4. Foreign Currency Considerations: Needed when transactions involve multiple currencies and specific exchange rate treatments

5. Cost Sharing Arrangements: Required when the agreement involves cost sharing between related entities

6. Business Restructuring Provisions: Include when future business restructuring might impact the transfer pricing methodology

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 methodology, including formulas, calculations, and examples

3. Schedule C - Critical Assumptions Details: Comprehensive list of critical assumptions with specific thresholds and parameters

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

5. Appendix 1 - Financial Data: Historical financial data and projections relevant to the transfer pricing methodology

6. Appendix 2 - Functional Analysis: Detailed analysis of functions, assets, and risks of involved entities

7. Appendix 3 - Comparable Company Analysis: Details of comparable companies and adjustments used in the methodology

8. Appendix 4 - Organizational Structure: Corporate structure and relationships between relevant entities