Annex B

This document (headed 'ANNIX II' in the scan, i.e., Annex B) is a completion guide for the summary section of an annexed tax-ruling template referred to as Annex A. It specifies what to include for each tax ruling: general background on the taxpayer requesting the ruling and its group and industry; the applicable regime (a reference to the particular regime, plus a short 1-2 sentence summary where the regime is not well known, generally without legislative references); a summary of the transaction or activity covered (e.g., transfer of goods, services, intangibles, financial assets, restructuring, cost contribution agreements); related-party transactions and amounts (if possible by country), the relationship with taxpayers impacted by the ruling, and the fiscal effects in the country issuing the ruling; and type-specific details for preferential regime rulings, unilateral APA/TP (transfer pricing) rulings, downward adjustment rulings, and permanent establishment (PE) rulings. It also calls for the outcome and status of the ruling (key conclusions of the tax authority; whether the ruling was issued pre- or post-transaction). The scan is heavily OCR-corrupted and the text is truncated.