Ireland Announces Updates To Transfer Pricing Rules

On 2 September 2019, the Irish Department of Finance issued a feedback statement outlining changes that will be made to the Irish transfer pricing rules with effect from 1 January 2020.  Irish transfer pricing rules apply to certain transactions entered into by associated parties.  The key changes to the Irish rules are summarised below:

• the transfer pricing rules will apply to non-trading transactions, save for certain Irish-to-Irish non-trading transactions;
• grandfathering that existed for transactions agreed before 1 July 2010 will be removed;
• the transfer pricing rules will begin to apply to capital transactions where the market value of the asset exceeds €25 million;