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Unilateral Advance Pricing Agreement

Unilateral Advance Pricing Agreement Template for Ireland

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Key Requirements PROMPT example:

Unilateral Advance Pricing Agreement

"I need a Unilateral Advance Pricing Agreement for my Irish technology subsidiary that licenses software IP from our US parent company, to be effective from January 2025, with particular attention to industry-standard royalty rates and the impact of rapid technological changes."

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Document background
The Unilateral Advance Pricing Agreement is a crucial document for multinational enterprises operating in Ireland seeking certainty in their transfer pricing arrangements. It is particularly relevant following the introduction of formal transfer pricing rules in Ireland through the Finance Act 2019. The document is used when a company wants to agree on a transfer pricing methodology with the Irish Revenue Commissioners for specific intercompany transactions, typically covering a period of 3-5 years. The agreement provides taxpayers with certainty regarding their transfer pricing arrangements while helping them avoid potential disputes with tax authorities. It includes detailed information about the proposed methodology, critical assumptions, compliance requirements, and specific terms governing the pricing of intercompany transactions. This type of agreement is especially important for companies with significant related-party transactions, intellectual property arrangements, or complex international operations.
Suggested Sections

1. Parties: Identification of the taxpayer and the Irish Revenue Commissioners

2. Background: Context of the application, including brief description of the business and proposed covered transactions

3. Definitions: Key terms used throughout the agreement, including technical transfer pricing terms

4. Scope of the Agreement: Specific transactions, products, or services covered by the APA

5. Term of Agreement: Duration of the APA, including start and end dates

6. Transfer Pricing Methodology: Detailed description of the agreed transfer pricing method and how it will be applied

7. Critical Assumptions: Fundamental assumptions upon which the APA is based

8. Annual Compliance Requirements: Reporting and documentation requirements to demonstrate compliance

9. Record Keeping Obligations: Specific records that must be maintained to support the APA

10. Revision and Cancellation: Circumstances and procedures for modifying or terminating the agreement

11. Confidentiality: Provisions regarding the confidential treatment of information

12. Governing Law: Confirmation of Irish law as the governing law of the agreement

Optional Sections

1. Renewal Provisions: Used when parties want to include specific terms for potential renewal of the APA

2. Rollback Provisions: Included when the methodology may be applied to previous tax years

3. Dispute Resolution: Included when specific dispute resolution procedures are needed beyond standard legal remedies

4. Force Majeure: Used when specific extraordinary circumstances need to be addressed

5. Related Party Transactions: Included when multiple related entities are involved in the covered transactions

6. Industry-Specific Provisions: Used when particular industry considerations need to be addressed

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

Suggested Schedules

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

2. Schedule 2 - Transfer Pricing Methodology Details: Technical details of the methodology, including calculations and examples

3. Schedule 3 - Critical Assumptions Detail: Comprehensive list and explanation of all critical assumptions

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

5. Appendix A - Financial Data: Historical financial data and projections supporting the proposed methodology

6. Appendix B - Functional Analysis: Detailed analysis of functions, assets, and risks of all parties

7. Appendix C - Comparability Analysis: Details of comparable transactions or companies used in the analysis

8. Appendix D - Organization Structure: Corporate structure and relationships between relevant entities

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Agreement
Arm's Length Principle
Arm's Length Range
Associated Enterprises
Covered Transaction(s)
Critical Assumptions
Compensating Adjustment
Comparable Uncontrolled Price
Comparable Uncontrolled Transaction
Controlled Transaction
Cost Plus Method
Effective Date
Financial Statements
Fiscal Year
Functions, Assets and Risks
Group
Independent Enterprise
Interquartile Range
Irish Revenue Commissioners
Material Change
OECD Guidelines
Operating Margin
Parent Company
Profit Level Indicator
Related Party
Resale Price Method
Review Period
Subsidiary
Tax Year
Term
Testing Party
Transfer Pricing Method
Transfer Pricing Documentation
Transactional Net Margin Method
Uncontrolled Transaction
Relevant Industries

Technology

Pharmaceuticals

Manufacturing

Financial Services

Telecommunications

Consumer Goods

Energy

Automotive

Life Sciences

Media and Entertainment

Professional Services

Software Development

Relevant Teams

Tax

Finance

Legal

Treasury

Transfer Pricing

International Tax

Corporate Development

Financial Planning & Analysis

Compliance

Risk Management

Strategic Planning

Relevant Roles

Tax Director

Chief Financial Officer

Transfer Pricing Manager

International Tax Manager

Head of Tax

Finance Director

Tax Counsel

Corporate Controller

Treasury Manager

Financial Planning Manager

Compliance Officer

Tax Partner

Managing Director

Chief Executive Officer

Industries
Taxes Consolidation Act 1997, Part 35A: The primary Irish legislation governing transfer pricing, including the legal basis for advance pricing agreements and the arm's length principle
Finance Act 2019: Updated transfer pricing rules in Ireland, expanding scope and incorporating 2017 OECD Guidelines
Irish Revenue Guidelines on Advance Pricing Agreements: Specific guidance from Irish Revenue on APA procedures, requirements, and administration
OECD Transfer Pricing Guidelines 2022: International guidelines followed by Ireland for transfer pricing methodology and documentation requirements
EU Treaty Articles 107-109: EU State aid rules that may affect the validity and implementation of APAs
Tax and Duty Manual Part 35A-01-01: Irish Revenue's detailed guidance on transfer pricing rules and documentation requirements
Taxes (Country-By-Country Reporting) Regulations 2015: Regulations regarding transfer pricing documentation and reporting requirements that may be relevant for APA documentation
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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