Advance Pricing Agreements

Overview

Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses was issued on 3 October 2022 and was published in Issue #737 of the Official Gazette of the United Arab Emirates ("UAE") on 10 October 2022. This Decree-Law together with its amendments is referred to as the "Corporate Tax Law".

The Corporate Tax Law provides the legislative basis for imposing a federal tax on corporations and Business profits in the UAE.

Purpose of the guide

This guide is aimed at providing guidance on procedural aspects of an Advance Pricing Agreement ("APA"), a mechanism available under the Corporate Tax Law and covers:

• Overview of the APA programme,

• APA procedures, and

• APA monitoring and review.

Who should read the guide?

This guide should be read by anyone responsible for the tax affairs of any Person, who seeks to obtain tax certainty by entering into an APA covering Controlled Transactions. It is intended to be read in conjunction with the Corporate Tax Law, the implementing decisions and other relevant guidance published by the FTA.

How to use the guide

The relevant Articles of the Corporate Tax Law and the implementing decisions are indicated in each section of the guide.

It is recommended that the guide be read in its entirety to provide a complete understanding of the definitions and interactions of the different rules.

Legislative references

In this guide, the following legislation shall be referred to as follows:

• Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments, is referred to as "Tax Procedures Law",

• Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments, is referred to as "Corporate Tax Law",

• Cabinet Resolution No. 44 of 2020 on Organising Reports Submitted by Multinational Companies, is referred to as "Cabinet Resolution No. 44 of 2020",

• Cabinet Decision No. 75 of 2023 on the Administrative Penalties for Violations Related to the Application of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments, is referred to as "Cabinet Decision No. 75 of 2023",

• Cabinet Decision No. 65 of 2020 on Fees for the Services Provided by the Federal Tax Authority, and its amendments, is referred to as "Cabinet Decision No. 65 of 2020", and

• Federal Tax Authority Decision No. 5 of 2021 on Issuing Clarifications and Directives, and its amendments, is referred to as "FTA Decision No. 5 of 2021".

Status of the guide

This guide is not a legally binding document, but is intended to provide assistance in understanding the APA programme under the Corporate Tax regime in the UAE. The information provided in this guide should not be interpreted as legal or tax advice. It is not meant to be comprehensive and does not provide a definitive answer in every case. It is based on the legislation as it stood when the guide was published. Each Person's own specific circumstances should be considered.

The Corporate Tax Law, the implementing decisions and the guidance materials referred to in this document will set out the principles and rules that govern the application of Corporate Tax in the UAE. Nothing in this publication modifies or is intended to modify the requirements of any legislation.

This document is subject to change without notice.

Overview of APAs

The APA programme offers a voluntary mechanism for a Person to enter into an agreement for determining the Arm's Length Price of Controlled Transactions over a period of time and preventing the risk of TP disputes and litigation.

The FTA encourages the adoption of the APA programme between the FTA and the Person. Key benefits of an APA include:

• Enhanced predictability: Enhances predictability regarding the tax treatment of Controlled Transactions for Tax Periods.

• Facilitated collaboration: Provides an opportunity to engage with the FTA in a cooperative environment.

• Prevention from risk of TP disputes: Reduces the need for time-consuming examinations of complex TP issues and mitigates the risk of tax litigations.

• Prevention of double taxation: Reduces or effectively eliminates double taxation through bilateral APAs.

• Streamlined compliance: Simplifies record-keeping by clearly outlining the required documentation to ensure compliance with the APA.

Types of APAs

An APA can be of the following types:

• Unilateral APA ("UAPA"): A UAPA is an agreement between a Person and the FTA for domestic and cross border Controlled Transactions. A UAPA between a Person and the FTA will provide the Person with an assurance on key criteria and assumptions to be followed for establishing the Arm's Length Price for the Controlled Transactions during the period covered under the APA.

  The UAPA shall be binding only on the FTA, and the Person that is a party to the UAPA, to provide tax certainty exclusively from a UAE Corporate Tax Law perspective. The UAPA is not binding on any foreign taxpayer or foreign tax administration that may be the counterparty to the Controlled Transactions covered by the UAPA. Accordingly, the terms and conditions agreed under the UAPA shall not be construed as enforceable or applicable beyond the jurisdiction of the UAE and shall not be binding on the foreign tax administration. For a domestic UAPA, counterparty to the covered Controlled Transactions should comply with the Arm's Length Price and other terms agreed in the UAPA. Further, during an audit of the counterparty, if any, the FTA will take into consideration the position agreed in the UAPA, unless additional facts are identified during the audit that are inconsistent with the understanding on which the UAPA was based.

  A Person may suffer double taxation if the foreign tax administration disagrees with the UAPA concluded with the FTA and makes adjustments to the transfer prices. The Person will then have to rely on other remedies to resolve the double taxation such as a Bilateral/Multilateral Advance Pricing Agreement ("BAPA/MAPA") or Mutual Agreement Procedure ("MAP").

  The UAPAs for cross border Controlled Transactions shall be exchanged with foreign tax administrations of the jurisdiction of ultimate parent entity, immediate parent entity and counterparty of Controlled Transactions. Where a Person obtains an APA from a foreign tax administration regarding the same Controlled Transactions, it is obliged to notify the FTA of the same.

  For domestic Controlled Transactions, the FTA shall accept the application for UAPAs from December 2025 and for cross-border Controlled Transactions, the commencement date will be announced in 2026.

• BAPA: A BAPA is an agreement between competent authorities of two jurisdictions reached through a MAP. A BAPA provides tax certainty in relation to Controlled Transactions in the UAE and the relevant foreign jurisdiction.

• MAPA: A MAPA is a set of agreements between competent authorities of more than two jurisdictions reached through a MAP. MAPAs offer significant tax certainty as compared to traditional BAPAs in situations involving more than two jurisdictions.

The FTA is introducing its APA programme in a phased manner, initially through UAPAs.

While the initial focus is on UAPAs, covering both domestic and cross-border Controlled Transactions, the FTA, along with the Competent Authority, is committed to further enhancing the programme by gradually expanding to BAPAs/MAPAs. This phased approach will ensure a strong foundation is laid through practical experience, stakeholder engagement, and capacity building, for effective and efficient mutual agreement for BAPAs/MAPAs with treaty partners.

Additional guidance will be issued upon implementation of BAPAs/MAPAs. The date of receiving APA applications other than UAPAs shall be announced in the future.

Scope of an APA

An APA will set out the criteria for determining the Arm's Length Price in relation to Controlled Transactions entered or to be entered by that Person, over a fixed period of time. The manner in which an Arm's Length Price is determined in an APA may include application of one or combination of the TP methods^[1] under the Corporate Tax Law, along with such adjustments or variations, as may be necessary to do so. At the initial stage, UAPAs shall only cover prospective periods.

An APA may among other elements, include:

• Parties to the APA,

• Controlled Transactions covered by the agreement,

• Tax Periods covered by the agreement,

• Agreed TP criteria for determining Arm's Length Price including the definition of any relevant terms to be used in the agreement,

• Critical assumptions, and

• Documentation and implementation mechanism.

An APA entered into shall be binding on:

• the Person in whose case and in respect of the Controlled Transactions in relation to which, the agreement has been entered into, and

• the FTA subject to conditions prescribed in Section 5.

Eligibility for an APA

A Person who has proposed or entered into domestic and/or cross-border Controlled Transactions is eligible to enter into an APA under the APA programme. However, such Controlled Transactions shall meet the materiality threshold prescribed in Section 3.5 to apply for an APA.

A Person may apply for an APA if there are significant uncertainties in determining the appropriate criteria for establishing the Arm's Length Price of proposed or existing Controlled Transactions. This could include cases involving complex Business operations or Controlled Transactions, or where such Controlled Transactions have been historically subject to audit. Controlled Transactions that fall under safe harbour provisions, including low value-adding intra-group services, shall not be taken into consideration for APAs.

Domestic Controlled Transactions may be covered under an UAPA if the Person and its domestic Related Party are subject to different tax rates or are eligible for any tax incentives under the Corporate Tax Law.

Domestic Controlled Transactions that may be covered under a UAPA include, but are not limited to, the following Controlled Transactions undertaken:

• by a Qualifying Free Zone Person with a Person based in mainland or vice versa,

• by a Business or Business Activity of a Government Entity,

• by a Business or Business Activity of a Government Controlled Entity that is not its Mandated Activities,

• between an Extractive Business and another Business of such Person, or

• between a Non-Extractive Natural Resource Business and another Business of such Person.

Materiality threshold to apply for an APA

A Person can apply for an APA with respect to domestic or cross-border Controlled Transactions, where the total/expected value of all the Controlled Transactions proposed to be covered under the APA is at least AED 100 million per Tax Period.

In determining the threshold of AED 100 million the Controlled Transactions of a Person must be at arm's length^[2] as calculated and proposed by the Person through its own analysis at the time of submitting the APA application.

The FTA will consider only the Controlled Transactions proposed for inclusion in the APA when assessing whether the threshold is met, unless the FTA specifically excludes certain transactions. For example, Controlled Transactions covered under safe harbour provisions shall be excluded from both the scope of the APA and the threshold calculation.

For a Tax Group, the threshold of AED 100 million shall apply at the level of the Tax Group. The value of all Controlled Transactions between the Tax Group and Related Parties outside the Tax Group shall be aggregated for the purpose of determining whether the threshold is met. Controlled Transactions between members of the Tax Group are generally eliminated when computing the Taxable Income of the Tax Group and shall not be considered for the threshold calculation. However, if any Controlled Transactions are required to be recognised for specific purposes under the Corporate Tax Law, such as for tax incentives, where applicable, they must be priced at arm's length, as calculated and proposed by the Person, and will be eligible for inclusion under both the scope of the APA and the threshold calculation.

However, meeting the materiality threshold is not the sole criterion for acceptance or rejection of an APA application. The FTA shall evaluate each request based on its specific facts and circumstances, including the complexity of the Controlled Transactions, the potential for tax risk, and the overall benefit of entering into an APA. This means that an application may still be rejected even if the threshold is met, or accepted even if the threshold is not met. The threshold is intended as an indicator of materiality, not an absolute requirement. If the value of the Person's Controlled Transactions is less than the threshold limit, they should provide a robust justification for why an APA would help ensure compliance and certainty in such cases.

Filing a pre-filing consultation and APA application

Subject to satisfaction of the eligibility criteria, a pre-filing consultation and APA application (collectively referred to as "APA Request") must be filed by a Person, its Tax Agent or Legal Representative on behalf of the Person.

Note that only a Tax Agent registered for Corporate Tax purposes with the FTA may submit the APA Request on behalf of the Person in the prescribed form.

In the case of a Tax Group, only the Parent Company of that Tax Group is permitted to submit the APA Request on behalf of the Tax Group or its members.

An APA Request submitted by any Person other than those mentioned above shall not be accepted.

Pre-filing consultation, APA application, or any other information required during the APA process can be submitted from 30 December 2025 by email to APA@tax.gov.ae, or via EmaraTax (from the date that shall be announced).

Critical assumptions underlying an APA

An APA sets out certain critical assumptions crucial for its validity, including aspects related to the Person applying for the APA, its Related Party, industry conditions, general economic factors.

Any changes to or breaches of these critical assumptions could render the APA ineffective. Appendix 1 contains a list of potential critical assumptions.

A Person must notify the FTA of any modifications or violations of the critical assumptions within 20 Business Days of the occurrence of such events, accompanied by a sufficient and reasonable justification for such modification or violation. The FTA shall then review the circumstances and engage with the Person to determine the appropriate course of action, which may include the revision, cancellation, or revocation of the APA.

Period of an APA

An APA shall be applied for a minimum of three Tax Periods and maximum of five Tax Periods. At the initial stage, UAPAs shall only cover prospective periods.

APA fees

An APA application shall be accompanied with a non-refundable fee of AED 30,000 at the time of filing the APA application. This fee is inclusive of any revisions/amendments (see Section 5.4) to the APA application.

In case of renewal of an APA (see Section 5.6), a Person is required to pay a non-refundable fee of AED 15,000.

Timeline of an APA application

A Person must submit the UAPA application within two months from the date of approval notification of pre-filing consultation by the Authority, or at least twelve months prior to the commencement of the first Tax Period to be covered under the UAPA, whichever is earlier.

The FTA shall endeavour to conclude an APA as soon as possible and within the best practice timelines prescribed by the OECD, subject to the timely submission of required information from the Person. Where the FTA requests the Person to submit further information or documentation, the Person is expected to submit such information or documentation within 40 Business Days from the date requested. The FTA will aim to request only the relevant information necessary for determining and concluding the APA. However, such information may also include details relating to other group entities or the wider group. The FTA shall use the information gathered during the APA process only for the purposes of the evaluation and conclusion of APA.

Stages of an APA

The stages of an APA process typically include the following:

• Stage 1 – Pre-filing consultation (see Section 4.1)

• Stage 2 – Filing of an APA application (see Section 4.2)

• Stage 3 – Evaluation and negotiation of the APA (see Section 4.3)

• Stage 4 – Concluding an APA and implementation (see Section 4.4)

Stage 1 – Pre-filing consultation

A Person proposing to enter into an APA must make a request to the FTA for a pre-filing consultation. This request should be made as per the prescribed form in Appendix 2.

A pre-filing consultation shall, inter-alia, address:

• scope of the APA, including proposed Controlled Transactions and period of APA,

• details of other Controlled Transactions not proposed to be covered,

• identification of the potential TP issues/ complexity,

• evaluation of suitability of proposed TP methodology and other terms proposed by the Person,

• any prior APAs in foreign jurisdictions covering the same Controlled Transactions or litigation history, and

• other relevant information.

A pre-filing consultation does not bind the FTA to enter into an APA, nor construe that the Person has applied for an APA.

Stage 2 – Filing of an APA application

A Person may proceed to submit an APA application upon receiving the notification to proceed with APA filing. The Person shall file the APA Application within two months from the date of notification by the FTA, or at least 12 months prior to the commencement of the first Tax Period to be covered under the APA, whichever is earlier. The APA application should include the following information:

• Controlled Transactions proposed to be covered,

• the Tax Period covered under the APA,

• the proposed TP method, proposed price and relevant analysis including industry analysis, functional and economic analysis, and

• the critical assumptions on which the Transfer Pricing methodology is based, etc.

The APA must be filed in the format specified by the FTA in Appendix 3.

Upon acceptance of an APA application, the FTA and the Person shall agree a project plan outlining the timelines for each stage of the process from commencement to conclusion of the APA.

Stage 3 – Evaluation and negotiation

Once site visits, interviews, meetings, and the collection of all required information and documents are complete, the FTA will commence its evaluation and analysis.

Stage 4 – Concluding an APA and implementation

Final version of an APA

The FTA shall discuss the implementation of the agreement with the Person. The FTA and the Person shall sign the APA agreement based on terms mutually agreed.

Withdrawal of APA application

A Person may withdraw their APA application at any point prior to the conclusion of the APA agreement. However, withdrawal, particularly at an advanced stage of the process and without valid justification, is discouraged due to the significant resource expenditure such actions entail. There shall be no refund of any fees paid.

Legal effect

An APA is binding on signatories to the APA with respect to the Controlled Transactions for the Tax Periods covered under an APA.

If the Person who entered into an APA complies with all terms and conditions of the APA, the FTA shall not contest the Arm's Length Price or the transfer pricing method applied to the Controlled Transactions covered under the APA for the Tax Periods specified in the APA. However, an APA does not establish a precedent for any other Tax Periods of the Person, nor for any other Person that is not covered under the APA.

Indicative UAPA timeline

Filing of an APA Annual Declaration

Any Person who has entered into an APA with the FTA is required to file an APA Annual Declaration for each Tax Period covered under the APA in the prescribed form provided in Appendix 4. This declaration should cover all aspects outlined in the APA including any terms and conditions specified therein.

The APA Annual Declaration shall be filed within 90 Business Days from the date of the signed APA or by the due date of filing each relevant Tax Return, whichever is later.

Review of APA Annual Declaration

The FTA may review the APA Annual Declaration to assess adherence to the terms and conditions agreed upon in the APA. Any review will primarily focus on verifying compliance with the APA's terms, conditions, facts, and circumstances, and will specifically examine whether:

• material representations in the APA application, the related documents, and the APA Annual Declaration remain valid and accurately describe the Person's operations and those of the Related Parties for the Tax Period under review,

• the agreed-upon most appropriate method has been consistently and accurately applied for the Tax Period being reviewed in accordance with the terms and conditions of the APA,

• supporting data and calculations used in applying the agreed-upon most appropriate method for the Tax Period is correct in all material respects, and

• critical assumptions underlying the APA remain valid and relevant.

Findings from the review of the APA Annual Declarations

The FTA shall notify the Person of any issues arising from the review. Depending on the nature of these issues the outcome may vary, i.e. no changes may be required to the APA, or it may result in a revision, subject to mutual agreement between the FTA and the Person. In cases where matters cannot be resolved, the APA may be cancelled. Additionally, revocation may occur, in case of the FTA's observation of any conditions outlined in Section 5.5.

Revision or cancellation of an APA

The FTA may revise an APA if there is:

• any change in law affecting the UAE Corporate Tax treatment of the Controlled Transactions covered under an APA,

• any change in Business, economic or any other relevant conditions, for example, entry or exit of Resident Persons from a Tax Group, which may necessitate an assessment of or modifications to the critical assumptions of the existing APA, and/or

• any other exceptional circumstances notified by the Person.

A Person must self-assess the need to revise an APA and furnish notification to the FTA within 20 Business Days from occurrence of such event.

The Authority may, at its discretion and based on information available, initiate revision of an APA upon becoming aware of any of the above circumstances that may impact the terms of the APA.

Based on its review of the Person's operations, the FTA may request further information and documents from the Person. Depending on the impact of changes, the FTA shall assess if any revision is required to the terms and conditions of the APA. If both parties, the FTA and the Person, agree to proceed with revisions of an APA, the new effective date shall be stated in the revised APA.

However, if the FTA determines that, due to the impact of the change, a revision is not feasible, or a revision is possible but the FTA and the Person are unable to reach a mutual agreement, the APA may be cancelled prospectively from the Tax Period in which the event occurred, while remaining effective for prior Tax Periods covered under the APA.

Revocation or cancellation of an APA

The FTA shall revoke or cancel an APA in any of the following cases:

• The Person made a material misrepresentation attributable to neglect, carelessness, or wilful default in the APA application or the APA Annual Declaration.

• The Person failed to comply with one or more material terms and conditions of the APA.

• The Person has breached one or more critical assumptions.

When the FTA revokes an APA:

• The revocation shall take effect from the first Tax Period covered under the APA.

• After the revocation becomes effective, the Controlled Transactions previously governed by the APA shall be subject to the provisions set forth in the Corporate Tax Law and Tax Procedures Law.

Depending on the severity of any breach or non-compliance, if the FTA decides to cancel the APA, it shall be cancelled prospectively from the Tax Period in which the breach or non-compliance occurred, as well as for all subsequent Tax Periods.

Renewal of an APA

A Person may opt for a renewal of an APA if there are no material changes in the Business operations and facts relating to the Controlled Transactions and if the critical assumptions remain valid. The Person shall file an APA renewal request with the required supporting documentation, including updated documents, analyses, and other relevant information, at least three months before the expiry of the existing APA.

The renewal request shall follow the same forms and procedures as the initial APA application, with the exception that a pre-filing consultation is not required and, therefore, the reduced fee applicable for renewal of APA shall apply.

Critical assumptions: the use of critical assumptions in the following areas identified below will depend on the facts and circumstances of each APA case. The areas below are not intended to be exhaustive, but merely identify key areas where critical assumptions may be required.

• Operational and economic critical assumptions: these critical assumptions are predominately related to how the Person undertakes their operations to limit material changes, where those changes may affect the underlying profitability of the Person, and may include:

  • how the Person defines, computes, allocates, and apportions costs and expenses,

  • limits on the amount and manner by which expenses and costs can vary,

  • limits on sales mixes, maximum sales amounts, projections of sales, and permissible sales trends and variations,

  • how new or disposed of related entities are treated, to what extent inventories can fluctuate, or to what extent covered purchases can be imported finished products

  • specific items to remain substantially the same, including customers, products, risks, functions, Business methods, assets, pricing policies, Business structure, presence and effect of a cost sharing agreement, functional currency, operating assets, presence or absence of intangible assets, intangible asset ownership, licensee agreements, specific personnel, location of specific personnel, presence or absence of commissions, and royalty amounts and percentages,

  • consistent exchange rates, interest rates, credit ratings and capital structure, and

  • no significant changes in market conditions, technology, product liability, product design, process design, and market share.

• Legal critical assumptions: these critical assumptions are predominantly related to ensure consistent legal and regulatory conditions and may include:

  • ensuring consistent external conditions relating to supervisory rights, customs duties, import and export restrictions, government regulatory requirements and maintenance of agreements in place (for example, distribution agreements),

  • maintaining current related and non-Related Party agreements, such as guarantees, warranties, product liability and debt obligations, and

  • keeping consistent shareholding ratios.

• Financial and tax related critical assumptions: these critical assumptions are predominantly related to ensure consistent financial and tax conditions and may include:

  • no substantial changes to the tax circumstances prevailing in either country, including significant tax reform,

  • limiting changes to the Person's estimated tax liability, period of limitation on assessment, tax effect of specified expenses, sourcing of income, permanent establishment, Foreign Tax Credit limitation; the ability to change a specified tax election or undertake tax consolidation (or fiscal unity), and, the ability to file for a refund,

  • limitations on system loss, intangible profit projections, buy-in payments, lack of currency risk, and valid business reasons for debt,

  • assumptions regarding the use of generally accepted accounting principles, such as favourable certified opinions, market to market accounting, consistency of accounting computations for all related parties, methods of accounting for foreign currency gains and losses, and unchanged methods for both financial and accounting, and

  • corrections to transfer prices by a third-party country not involved in the APA which influence the APA.

• Other assumptions: these are critical assumptions that generally, will be reflected in every APA, these may include:

  • the Business Activities, functions performed, assets employed and risks assumed, financial and accounting methods and classifications (including estimates) of a Person in relation to the Controlled Transactions covered under the APA, will remain materially the same as described or used in the APA application,

  • the organisational structure of the Person and the Related Parties remain substantially the same, as described in their APA application,

  • the accounting policies, procedures, and practices of the Person and its Related Parties remain substantially the same as those described in the APA application,

  • the working capital levels (such as accounts receivable, accounts payable and inventory) of the Person and Related Parties do not vary significantly from those levels existing when the transfer pricing method for the Controlled Transactions were established,

  • the Person and Related Parties have no exposure to extraordinary items or the sharing of losses arising in other entities, other than that exposure arising from its own decision-making and activities, and

  • neither the Person nor its Related Parties have intangible property that either directly or indirectly affects the Controlled Transactions that are covered under the APA.

About the Person

APA details

Details of the Person’s authorised signatory

Review and Declaration

I confirm that I have been granted full authority to complete this form on behalf of the relevant Person.

I confirm that the information provided in this form, including any attachments, is to the best of my knowledge complete and accurate at the date of submission.

Signature:Date:

Note:

All relevant documents/analyses/agreements should be enclosed with this request form at the time of submission.

About the Person

APA details

Note 1 – Cross border UAPAs are subject to Exchange of Information in accordance with the Organisation for Economic Cooperation and Development Base Erosion and Profit Shifting Action Five, and the Competent Authority is required to exchange a summary of the APA with foreign tax administrations of relevant countries, based on international requirements. Accordingly, please provide the relevant information requested in the 'Spontaneous Exchange of Information' section.

Details of the Person's authorised signatory

Review and Declaration

I confirm that I have been granted full authority to complete this form on behalf of the relevant Person.

I confirm that the information provided in this form, including any attachments, is to the best of my knowledge complete and accurate at the date of submission.

Signature:Date:

Note:

All relevant documents/analyses/agreements should be enclosed with this request form at the time of submission.

I am submitting herewith Annual APA Declaration for the period beginning from dd/mm/yyyy to dd/mm/yyyy for the Advance Pricing Agreement entered into between (Name of the Person) and the Federal Tax Authority vide APA Reference No. ............................ dated ……………. In this regard, I provide below the necessary information.

About the Person

Content of the declaration:

Details of the Person's authorised signatory

Review and Declaration

I confirm that I have been granted full authority to complete this form on behalf of the relevant Person.

I confirm that the information provided in this form, including any attachments, is to the best of my knowledge complete and accurate at the date of submission.

Signature:Date:

Note:

All relevant documents/analyses/agreements should be enclosed with this request form at the time of submission.

APA Annual Declaration checklist for attachments:

1. All appropriate information and computations that clearly show how the selected Transfer Pricing methods were applied.

2. Audited Financial Statements for the relevant Tax Period.

3. Reconciliation statement of all adjustments made between the net income in the audited Financial Statements and the taxable income disclosed in the Tax Return (if applicable).

4. Any other appropriate document or information necessary to validate if agreed APA terms have been complied with.