Formal transfer pricing legislation was introduced in Ireland
for the first time in 2010. The transfer pricing regime applies for
accounting periods commencing on or after 1 January 2011, for
transactions the terms of which were agreed on or after 1 July
2010.
Whilst Ireland's transfer pricing rules are therefore still
relatively new, transfer pricing is becoming an increasing
important issue to consider for multinationals operating in
Ireland.
Broadly speaking, Ireland's transfer pricing rules require
domestic and international transactions between associated persons
undertaken in the course of trading activities to be entered into
at arm's length. Where an arrangement between associated
entities is made otherwise than at arm's length, an adjustment
may be made to the Irish company profits. An adjustment is only
made where income is understated or expenses are overstated. The
transfer pricing legislation specifically provides that the
transfer pricing rules
