1. Multilateral Considerations: Required when the APA involves multiple tax jurisdictions, addressing interaction with foreign tax authorities

2. Compensating Adjustments: Include when there's a need to specify procedures for making retrospective adjustments to achieve the agreed price range

3. Dispute Resolution: Detailed dispute resolution procedures, recommended for complex APAs or when multiple jurisdictions are involved

4. Force Majeure: Include when parties want to address how extraordinary events might affect the application of the transfer pricing methodology

5. Language: Required when parties are from different jurisdictions to specify the prevailing language of the agreement

6. Associated Enterprises: Include when the APA affects multiple related entities within a corporate group

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 Analysis: Detailed analysis and parameters of the critical assumptions

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

5. Schedule E - Financial Projections: Relevant financial projections and benchmarking data

6. Appendix 1 - Reporting Templates: Templates for annual compliance reporting

7. Appendix 2 - Supporting Documentation: List of required supporting documentation and maintenance requirements

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