1. Rules Governing Transfer Pricing
1.1 Statutes and Regulations
Ireland's transfer pricing rules are set out in Part 35A of
the Taxes Consolidation Act 1997 (TCA) (the "TP Rules").
Part 35A was introduced in the Finance Act 2010, and was
substantially amended by the Finance Act 2019 and then further
amended by the Finance Act 2020, the Finance Act 2021 and the
Finance Act 2022. Prior to the Finance Act 2019, transactions
agreed before 1 July 2010 were outside the scope of the TP Rules;
however, with effect for chargeable periods commencing on or after
1 January 2020, the TP Rules apply to transactions agreed before
this date.
The Finance Act 2022 updated the definition of "transfer
pricing guidelines" to refer to the 2022 version of the OECD
Transfer Pricing Guidelines (the "TP Guidelines"), which
incorporates the OECD's Revised Guidance on the Transactional
Profit Split Method, Guidance for Tax Administrations on the
Application of the Approach to
