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ARTICLE · 09 JULY 2021

Irish Transfer Pricing Documentation – What Do You Need To Know?

Grant Thornton
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The new Irish Transfer Pricing rules introduced by Finance Act 2019 apply to Accounting Periods starting on or after 1 January 2020.

IrelandTax
Anthony Crewe
Anthony Crewe

Background

The new Irish Transfer Pricing (TP) rules introduced by Finance Act (FA) 2019 apply to Accounting Periods starting on or after 1 January 2020. The accounts for the first period covered by the rules are being prepared and audited right now. Are you aware of the new requirements?

Revenue published TP guidance in February 2021 (Part 35A-01-01 of the Tax and Duty Manual) which provides additional details for taxpayers on how the rules will apply. One of the main aspects of the updated guidance is in respect of TP documentation and the requirements to be satisfied in order to comply with the new rules.

Revenue have also revised the tax return from FY2020 onwards to include TP related questions. For example, it is now necessary to tick a box on the tax return confirming whether a local file or master file has been prepared. It can be expected that companies with a documentation requirement but unable to tick these boxes may find themselves the subject of

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