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Unilateral Advance Pricing Agreement

Unilateral Advance Pricing Agreement Template for India

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Key Requirements PROMPT example:

Unilateral Advance Pricing Agreement

"I need a Unilateral Advance Pricing Agreement for my Indian manufacturing subsidiary that uses the Cost Plus Method for pricing intercompany raw material purchases from our UK parent company, to be effective from April 1, 2025."

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Document background
The Unilateral Advance Pricing Agreement is a crucial document for multinational enterprises operating in India who seek to establish certainty in their transfer pricing arrangements. It represents a proactive approach to tax compliance and dispute prevention, allowing companies to agree on transfer pricing methodologies with the Indian tax authorities in advance. The agreement is particularly valuable for companies with significant inter-company transactions and those seeking to minimize transfer pricing risks in India. The document typically includes detailed methodologies, critical assumptions, and compliance requirements, and is binding on both the taxpayer and the tax authority for the specified period. This type of agreement has gained significance in India since its introduction in 2012, offering businesses a way to avoid protracted transfer pricing disputes while ensuring compliance with Indian transfer pricing regulations.
Suggested Sections

1. Parties: Identification of the taxpayer and the Central Board of Direct Taxes (CBDT)

2. Background: Context of the application, brief description of the business operations and international transactions covered

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

4. Scope of Agreement: Specific international transactions covered under the APA

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

6. Transfer Pricing Methodology: Agreed method(s) for determining the arm's length price

7. Critical Assumptions: Fundamental assumptions underlying the APA's continued validity

8. Compliance Requirements: Annual compliance reporting obligations and documentation requirements

9. Revision and Cancellation: Circumstances and procedures for revision or cancellation of the APA

10. Confidentiality: Provisions regarding the confidentiality of information shared

11. Governing Law and Jurisdiction: Specification of Indian law as governing law and jurisdiction

12. Execution: Signature blocks and execution formalities

Optional Sections

1. Rollback Provisions: Include when the taxpayer opts for applying the APA methodology to previous years

2. Dispute Resolution: Include when specific dispute resolution mechanisms beyond standard legal recourse are needed

3. Force Majeure: Include when protection against unforeseen events affecting compliance is required

4. Multiple Transaction Categories: Include when different methodologies apply to different categories of transactions

5. Mutual Agreement Procedure Interface: Include when there's potential interaction with treaty partner countries' competent authorities

6. Economic Adjustments: Include when specific economic adjustments to the transfer pricing methodology are agreed upon

Suggested Schedules

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

2. Schedule B - Transfer Pricing Methodology: Detailed explanation of the agreed methodology, including calculations and examples

3. Schedule C - Critical Assumptions Analysis: Detailed analysis of each critical assumption and its impact

4. Schedule D - Annual Compliance Report Format: Template and instructions for annual compliance reporting

5. Appendix 1 - Financial Analysis: Historical financial data and projections supporting the transfer pricing methodology

6. Appendix 2 - Functional Analysis: Detailed analysis of functions, assets, and risks of the parties involved

7. Appendix 3 - Comparability Analysis: Analysis of comparable transactions or companies used in the methodology

8. Appendix 4 - Supporting Documentation: List of all supporting documents referenced in the APA

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok³ÉÈË°æ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions




































Clauses































Relevant Industries

Manufacturing

Information Technology

Pharmaceutical

Automotive

Financial Services

Telecommunications

Consumer Goods

Energy and Resources

Professional Services

E-commerce

Relevant Teams

Finance

Tax

Legal

Compliance

Risk Management

International Operations

Corporate Strategy

Treasury

Accounting

Relevant Roles

Chief Financial Officer

Tax Director

Transfer Pricing Manager

International Tax Manager

Finance Controller

Tax Compliance Manager

Corporate Finance Manager

Financial Planning Analyst

Tax Counsel

Finance Director

Risk Management Officer

Compliance Officer

Industries









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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