ARTICLE · 14 DECEMBER 2012

Transfer Pricing Compliance Review - Client Update

Matheson

Explore more from Matheson

Transfer pricing compliance reviews will form the cornerstone of the Irish Revenue Commissioners approach to monitoring compliance with the Irish transfer pricing rules.

IrelandTax

Author LinkedIn connections

Irish transfer pricing compliance measures

Transfer pricing compliance reviews ("TPCRs") will form the cornerstone of the Irish Revenue Commissioners ("Irish Revenue") approach to monitoring compliance with the Irish transfer pricing rules. Our transfer pricing team met with Irish Revenue in advance of the publication of the formal guidance by Irish Revenue on these new measures where it was confirmed that notifications under the TPCR system are set to issue to Irish taxpayers over the next couple of weeks. The initial focus of Irish Revenue will be on those taxpayers who are within the Large Cases Division.

Main features of TPCRs

The main features of the TPCR are as follows:

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Tax Simplification Omnibus – Simplifying EU Tax Rules, Reducing Compliance Burdens

Budget 2027: Five Key Takeaways For Private Equity In Ireland

William Fry LLP

The Finance (No. 2) Bill 2026: What You Need To Know

Key Details Of The New Irish Individual Investment Account Unveiled In Finance (No. 2) Bill 2026

Irish Budget 2027: Key Tax Measures For The Financial Services Industry

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Transfer Pricing

Related Comparative Guides

Comparative Guide

Tax

Comparative Guide

Tax Disputes

See more popular content from

Tax

Budget 2027

Ireland's Budget 2027, announced on 6 October 2026, introduces a €1.3 billion personal income tax package and projects a €9.5 billion surplus while implementing significant changes to capital gains tax...

William Fry LLP

Irish Budget 2027: Key Tax Measures For The Financial Services Industry

Ireland's Budget 2027 introduces a lower exit tax rate for fund investors, clearer rules for Irish ETFs, and a new Retail Investment Account, while leaving the controversial eight-year deemed disposal rule unchanged. The package also includes Pillar Two updates, interest relief reforms, and a capital gains tax reduction, offering targeted refinements for the financial services sector rather than the fundamental reform many had anticipated.

Ireland Budget 2027 – Tax Highlights

Ireland's Budget 2027 introduces significant tax reforms aimed at boosting competitiveness and encouraging investment, including reductions in capital gains tax, simplified interest relief provisions, and a new Personal Investment Account with favorable tax treatment. The budget package totals €8.5 billion with measures focused on rewarding work, promoting entrepreneurship, and addressing housing supply challenges.

Corporate Tax 2025 - Ireland

Most often, businesses gravitate towards the LTD model due to its familiarity and simplicity. However, DACs and Irish Collective Asset Management Vehicles...

EU Customs Reform: New Union Customs Code Published

The European Union has enacted its most sweeping customs reform since 1968, fundamentally reshaping how businesses import and export goods across EU borders. The new Union Customs Code introduces stricter compliance requirements, shifts liability to importers and exporters, and establishes a centralized EU Customs Data Hub that will eventually become mandatory for all economic operators.

European UnionTax

The DAC Recast – Delivering Meaningful Tax Simplification

The European Commission has proposed consolidating nine separate Directives on Administrative Cooperation into a single recast directive, aiming to simplify the EU's tax information exchange framework while maintaining transparency. However, the proposal faces significant challenges including the incorporation of previously rejected "Unshell" provisions, the requirement for unanimous approval from all 27 Member States, and questions about whether the consolidation will deliver meaningful simplification for

European UnionTax

Irish Budget 2026 – Implications For Irish And International Investors

The Irish Budget for 2026 was announced by Minister Pascal Donohoe on 7 October 2025.

Statutory Codification Of Foreign Entity Tax Classification In Ireland

Ireland has introduced Section 1009A of the Taxes Consolidation Act 1997, marking the first time Irish legislation directly addresses the tax transparency of foreign entities. This groundbreaking provision has significant implications for cross-border investment structures involving Irish funds, particularly those utilizing Delaware limited partnerships, U.K. LLPs, and U.S. LLCs, with downstream consequences for Pillar 2 and anti-hybrid mismatch rules.

Irish Budget 2027 – Implications For Irish And International Investors

The Irish Budget for 2027 (“Budget 2027”) was announced by Minister Simon Harris on 6 October 2026. Budget 2027 contains a number of measures intended to support Ireland’s status as a leading financial and investment jurisdiction in Europe. International investors will welcome the introduction of reforms for the taxation of Irish corporates, the introduction of new rules to accommodate the Pillar Two side-by-side agreement with the US and the extensions to Irish tax provisions for tax credits.

What The High Court’s New AI Guidance Means For Irish Tax Appeals

Ireland's High Court has issued formal guidance on using generative AI in legal proceedings, requiring human oversight, verification, and disclosure when AI tools are employed in court documents and expert reports. While the directive specifically applies to High Court proceedings, its implications extend to Tax Appeals Commission cases, where expert evidence must remain independent and any substantial use of AI must be declared to ensure reliability and evidential weight.