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ARTICLE · 16 JULY 2024

Tax Appeals Commission Issues Its First Transfer Pricing Determination

A&L Goodbody LLP
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A recently published determination of the Tax Appeals Commission (TAC), 59 - TACD - 2024, has considered the issue of transfer pricing adjustments in Ireland for the first time.

IrelandTax
Amelia O'Beirne
Amelia O'Beirne
Cian Ryan
Cian Ryan

A recently published determination of the Tax Appeals Commission (TAC), 59 - TACD - 2024, has considered the issue of transfer pricing adjustments in Ireland for the first time.

Background

This matter involved an appeal by a taxpayer company against four amended assessments for corporation tax, raised by the Revenue Commissioners (Revenue) for the 2015 to 2018 tax years. Specifically, Revenue had sought transfer pricing adjustments in relation to the taxpayer company's supply of services to its non-Irish tax resident parent company, which is active in the software development sector, in accordance with s.835C(2)(b) of the Taxes Consolidation Act 1997 (TCA). These adjustments related to share based awards (SBAs) granted by the parent company to employees of the taxpayer company.

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