ARTICLE · 30 MAY 2023

Chambers Transfer Pricing 2023

Matheson

Explore more from Matheson

Matheson partners Catherine O'Meara and Joe Duffy, and senior associate Anna Crowley recently contributed to the Chambers Transfer Pricing 2023 Global Practice Guide Ireland Chapter.

IrelandTax

Catherine O'Meara

Joe Duffy

Anna Crowley

Author LinkedIn connections

Matheson partners Catherine O'Meara and Joe Duffy, and senior associate Anna Crowley recently contributed to the Chambers Transfer Pricing 2023 Global Practice Guide Ireland Chapter.

The guide provides the latest legal information on the Irish approach to transfer pricing issues, including commentary on transfer pricing rules, cross-border information sharing, advance pricing agreements and other cross border dispute resolution mechanisms, penalties, safe harbours and the impact of COVID-19.

Originally Published by Chambers and Partners in new window, April 2023

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

InDisputes – TAC Considers Tax Treatment Of Pension Arrears

The DAC Recast – Delivering Meaningful Tax Simplification

European UnionTax

InDisputes – TAC Considers Redundancy Payment Tax Exemption

Roadmap For The Taxation Of Retail Investment Published: Funds Perspective

Recasting DAC: Simplification Meets Political Reality

Read more about

Tax
- Transfer Pricing

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

Tax

InDisputes – TAC Considers Tax Treatment Of Pension Arrears

The Tax Appeals Commission has ruled on a case involving pension arrears paid years after they were earned, determining how such lump-sum payments should be taxed under Irish law. The decision addresses whether backdated pension payments should be taxed in the year they relate to or the year they are actually received, with significant implications for taxpayers receiving delayed retirement benefits.

The DAC Recast – Delivering Meaningful Tax Simplification

The European Commission has proposed consolidating nine separate Directives on Administrative Cooperation into a single recast directive, aiming to simplify the EU's tax information exchange framework while maintaining transparency. However, the proposal faces significant challenges including the incorporation of previously rejected "Unshell" provisions, the requirement for unanimous approval from all 27 Member States, and questions about whether the consolidation will deliver meaningful simplification for

European UnionTax

InDisputes – TAC Considers Redundancy Payment Tax Exemption

The Tax Appeals Commission examined whether an employee working in Ireland under an A1 certificate, who paid social security contributions in another EU jurisdiction rather than Irish PRSI, could claim tax exemption on a redundancy payment. The case centered on the interpretation of the Redundancy Payments Act 1967 requirements and whether EU Regulation 883/2004 on social security coordination could override Irish tax law provisions for statutory redundancy payments.

Roadmap For The Taxation Of Retail Investment Published: Funds Perspective

The Irish Department of Finance has unveiled a comprehensive roadmap to transform how retail investors are taxed, with a new investment account at its core designed to simplify the tax framework and encourage greater participation in capital markets. The proposal includes annual contribution limits, a tax-free threshold, and a flat-rate tax structure that eliminates the controversial deemed disposal rule, while also signaling broader reforms to investment fund taxation from Budget 2028 onwards. This initiat

Recasting DAC: Simplification Meets Political Reality

The European Union has proposed a comprehensive recast of its Directive on Administrative Cooperation (DAC), aiming to consolidate nine existing directives into a single framework while addressing longstanding concerns about reporting burdens.

Behind The Scenes Of Ireland’s EU Presidency: Insights From Rory Montgomery (Podcast)

Ireland's EU Presidency brings unique insights into European legislative processes, while recent tribunal decisions and regulatory changes reshape the landscape for tax enquiries, transfer pricing adjustments, and foreign investment screening. These developments signal important shifts in how tax authorities exercise their powers and how cross-border transactions are scrutinized across EU member states.

Ireland’s Presidency Of The Council Of The European Union

Ireland assumes the Presidency of the Council of the European Union with an ambitious agenda centered on competitiveness, values, and security.

InDisputes: Irish Tax Appeals Lookback To 2025 And Possible Change Signalled

The Tax Appeals Commission's 2025 annual report reveals significant trends in Irish tax dispute resolution, including a fourfold increase in appeal values and growing complexity of cases involving European law. With corporation tax disputes representing 64% of the quantum despite only 5% of appeals, and proposed legislative changes potentially shifting to public hearings, taxpayers face an evolving landscape requiring early preparation and strategic readiness.

CJEU Delivers Further Ruling On VAT Treatment Of Transfer Pricing Adjustments

The Court of Justice of the European Union has ruled on whether intra-group transfer pricing adjustments constitute consideration for separate supplies of services subject to VAT. While the judgment provides clarity on routine profit margin adjustments, it raises questions about the broader treatment of year-end transfer pricing adjustments and their VAT implications for multinational enterprises.

European UnionTax

Revenue Information Powers: Lessons From Lifeplus V HMRC

The Irish Revenue Commissioners are increasingly exercising their statutory powers to compel taxpayers to produce documents and information, both for domestic tax enquiries and in response to exchange of information requests from foreign tax administrations. A recent UK First-Tier Tribunal decision in Lifeplus Europe Ltd v HMRC provides valuable guidance on the scope and limits of these information-gathering powers, particularly regarding the concepts of 'reasonably required' and 'possession or power' in th