The Irish Revenue Commissioners
("Revenue") published updated
transfer pricing guidance in February 2021 (the
"Guidance"), which includes an overview
on the enhanced transfer pricing documentation requirements which
apply for chargeable periods commencing on or after 1 January 2020.
In addition to keeping records which demonstrate compliance with
the transfer pricing legislation, larger taxpayers will now have to
prepare a 'master file' and 'local file'.
The Guidance follows updated OECD Guidelines published in July
2017 which includes further information on the transfer pricing
documentation requirements (the "OECD
Guidelines").
This article provides a summary of the enhanced documentation
requirements envisaged by the Guidance.
