TaxTMI 
TaxTMI 
Application for an Advance Pricing Agreement
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....s) of the business enterprises in India: f. Email Id and the contact numbers of the person with whom correspondence is required to be made: g. Names and designation of the authorised representatives who would be appearing before the authorities for negotiations of the APA: 2. Whether pre-filing discussions were sought by the applicant? If yes, please furnish: a. Date of application for pre-filing meeting: b. Date of pre-filing meeting(s) with the APA Team: 3[3. Particular(s) of the Associated Enterprises with whom the APA is requested for: a. Name(s) of the Associated Enterprise(s): b. Name(s) of the country(ies) in which the associated enterprises mentioned in clause (a) are located: c. Taxpayer Registration Number/ Taxpaye....
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....h the other Competent Authority: d. If no, by what date the application is proposed to be furnished to the other Competent Authority: e. If the application is for Unilateral APA and it involves international transactions with an entity located in a jurisdiction with which India has an agreement under section 90 or 90A of the Act for avoidance of double taxation, kindly provide explanation for why the request is not for bilateral or multilateral APA. f. whether any rollback request is being made 2 Yes/ No g. if yes, enclose copy of relevant Form No. 3CEDA 2 6. Particulars of Fee paid by the applicant: Amount in Rs. Challan No. : Dated: 7. Period of APA proposed along with the date from which APA is sought to be applicable: 8. Detail....
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....tatements on a consolidated and unconsolidated basis for the prior five years, or the most recent business cycle as appropriate (Also provide interim statements for the most recent period prior to the date of the submission): b. Income-tax returns and related supporting schedules for the prior three years including Form 3CEB: c. Operating data (gross and net) segmented by product line, division, unit, and geographic region for the prior five years, or the most recent business cycle as appropriate: 20. Relevant marketing and financial studies: (Please enclose copies) 21. Copies of all relevant inter-company agreements (pricing, cost sharing, licensing, distributorship etc.): (Please enclose copies) III. Industry and market analyses 22.....
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....ing Methodology analysis 30. Provide all information, including detailed analyses and explanations needed to establish the appropriateness of a proposed TPM, in accordance with transfer pricing regulations as contained in the Indian Income-tax law: 31.Discussion and analysis of each transfer pricing method, applied or rejected, for each covered transaction. In particular provide details on accepted or rejected internal comparables. (Indicate assumptions, strategies, and policies that may have influenced the acceptance or rejection of each TPM): 32. Summary of selected TPMs and secondary TPMs, if used as a sanity check: VI. Impact of proposed TPMs 33. Application of the proposed TPMs to the covered transactions for the three prior years....