ARTICLE · 15 MAY 2024

New Guidance On Ireland's APA Programme

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On 26 April 2024, the Revenue Commissioners ("Revenue") published an updated version of the Bilateral Advance Pricing Agreement Guidelines (the "New Guidance").

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Catherine O'Meara

Caroline Austin

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1. Introduction

On 26 April 2024, the Revenue Commissioners ("Revenue") published an updated version of the Bilateral Advance Pricing Agreement Guidelines (the "New Guidance"). The New Guidance is intended to reflect OECD best practice on Bilateral Advance Pricing Agreements ("APA").

While a number of the updates are administrative in nature, the New Guidance offers enhanced details on taxpayer compliance requirements within the APA programme, in addition to providing some useful clarifications.

Ireland's APA programme is growing in significance as taxpayers face international transfer pricing disputes and need an experienced competent authority, such as the Irish Competent Authority (the "Irish CA"), to resolve cases effectively. In 2023, 16 new APA requests were received by the Irish CA, bringing the total number of APAs under negotiation to 68 at the end of 2023¹. This increase in the number of taxpayers seeking to enter into the APA programme highlights

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