ARTICLE · 14 FEBRUARY 2022

Irish Transfer Pricing Update – February 2022

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In a welcome move, Finance Act 2021 has reformed the existing exemption from transfer pricing for certain domestic transactions. As discussed in our previous update, the application of this exemption had given rise to ...

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Catherine O’Meara

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In this update, we discuss a number of key recent developments relevant to Ireland's transfer pricing regime.

Exemption for domestic transactions

In a welcome move, Finance Act 2021 has reformed the existing exemption from transfer pricing for certain domestic transactions. As discussed in our previous update, the application of this exemption had given rise to interpretive difficulties for practitioners and taxpayers alike, particularly in the context of transactions with nil consideration.

With effect for accounting periods commencing on or after 1 January 2022, the scope and application of the exemption from transfer pricing is now significantly clearer. In order for a transaction to be eligible to benefit from the exemption, the following main conditions must now be satisfied:

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