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ARTICLE · 24 MAY 2021

Ireland's New Transfer Pricing Rules – Practical Considerations For FY2020 TP Compliance Obligations

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Ireland's transfer pricing rules were significantly overhauled with effect from 1 January 2020. The Irish Revenue Commissioners published new guidance on the application of these rules in February 2021.

IrelandTax
Catherine O’Meara
Catherine O’Meara
Raphael Clancy
Raphael Clancy
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Ireland's transfer pricing rules were significantly overhauled with effect from 1 January 2020. The Irish Revenue Commissioners ("Irish Revenue") published new guidance on the application of these rules in February 2021. We outline here the key practical impacts that taxpayers need to be aware of when considering their corporation tax filing position for 2020 and future years.

Key Takeaways

  • The scope of the transfer pricing rules were expanded significantly so that many (previously exempt) transactions are now subject to the rules.
  • The transfer pricing documentation requirements have been enhanced, with incentives for preparing documentation on time and penalties for non-compliance.

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