Bilateral Advance Pricing Agreement Template for Hong Kong

1. Rollback Provisions: Optional provisions for applying the agreed methodology to previous tax years

2. Compensating Adjustments: Procedures for making adjustments to achieve the agreed pricing outcomes, if needed

3. Force Majeure: Provisions for handling extraordinary events that may impact the agreement's application

4. Multiple Party Provisions: Additional provisions when more than two entities are involved in the covered transactions

5. Interaction with Other Agreements: Provisions addressing interaction with other existing agreements or APAs

6. Special Industry Considerations: Specific provisions relevant to particular industries or business models

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

2. Schedule B - Transfer Pricing Methodology Details: Detailed technical explanation of how the chosen methodology will be applied

3. Schedule C - Financial Projections: Relevant financial projections and assumptions underlying the agreement

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

5. Schedule E - Critical Assumptions Detail: Comprehensive explanation of critical assumptions and their parameters

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

7. Appendix 2 - Supporting Documentation: List and copies of key supporting documents referenced in the agreement

8. Appendix 3 - Organizational Structure: Relevant corporate structure diagrams and relationships between parties