Advance Price Agreement Template for Germany

1. Multilateral Considerations: Required when the APA involves multiple tax jurisdictions, detailing how different tax authority requirements will be coordinated

2. Industry-Specific Provisions: Needed when special industry considerations affect the transfer pricing methodology

3. Rollback Provisions: Include when the methodology will be applied to previous tax years

4. Dispute Resolution: Additional procedures for resolving disagreements, particularly relevant in bilateral or multilateral APAs

5. Force Majeure: Include when specific provisions for extraordinary events affecting the critical assumptions are needed

6. Language: Required when multiple official versions in different languages exist

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

2. Schedule B - Transfer Pricing Methodology Details: Technical details of calculations, including formulas, profit level indicators, and comparable company analysis

3. Schedule C - Critical Assumptions Details: Detailed explanation of critical assumptions and quantitative thresholds

4. Schedule D - Annual Reporting Template: Format and requirements for annual compliance reports

5. Appendix 1 - Corporate Structure: Organization chart and description of relevant group entities

6. Appendix 2 - Financial Data: Historical financial data and projections relevant to the transfer pricing methodology

7. Appendix 3 - Functional Analysis: Detailed analysis of functions, risks, and assets of involved entities

8. Appendix 4 - Economic Analysis: Supporting economic analysis, including comparability studies and market data