1. Multilateral Considerations: Required when the ATPA involves multiple tax jurisdictions, addressing cross-border implications

2. Industry-Specific Provisions: Needed when special considerations apply to particular industries (e.g., automotive, pharmaceuticals)

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

4. Force Majeure: May be included to address extraordinary circumstances affecting the application of the agreed methodology

5. Related Party Services: Required when specific intra-group services are part of the transfer pricing arrangement

6. Intellectual Property Provisions: Needed when IP transfers or licenses are part of the covered transactions

7. Currency and Exchange Rate Provisions: Include when transactions involve multiple currencies and exchange rate considerations

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

2. Schedule B - Transfer Pricing Methodology Details: Detailed technical explanation of how the transfer pricing methods will be applied

3. Schedule C - Financial Projections: Expected financial outcomes and benchmarks for the covered transactions

4. Schedule D - Documentation Requirements: Specific documentation and evidence required to demonstrate compliance

5. Appendix 1 - Functional Analysis: Detailed analysis of functions, assets, and risks of all parties involved

6. Appendix 2 - Comparable Analysis: Analysis of comparable transactions or companies used in the methodology

7. Appendix 3 - Critical Assumptions Detail: Detailed explanation of each critical assumption and its parameters

8. Appendix 4 - Organizational Structure: Corporate structure diagram and explanation of relevant entity relationships