ARTICLE · 04 FEBRUARY 2019

Transfer Pricing For The International Practitioner

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The Irish Finance Bill 2018 (the ‘‘2018 Bill'') introduced a legislative amendment with respect to the application of domestic time limits under the Mutual Agreement Procedure (‘‘MAP'').

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Catherine O’Meara

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Legislation (e.g., new legislation or regulations that have impacted the transfer pricing landscape in your country.)

The Irish Finance Bill 2018 (the ''2018 Bill'') introduced a legislative amendment with respect to the application of domestic time limits under the Mutual Agreement Procedure (''MAP''). Section 57 of the 2018 Bill amends section 959AA of the Taxes Consolidation Act 1997 (''TCA'') which provides for time limits on assessments made or amended by a Revenue Officer. This provision should come into force once the Bill is enacted, i.e., before the end of 2018. When seeking MAP assistance with regard to adjustments made to previous financial years, in circumstances where the Double Taxation Agreement (''DTA'') remains silent as to the time limit for when a request for MAP assistance is to be brought, the OECD Model Tax Convention on Income and on Capital (''OECD MTC'') allows contracting states to the DTA to be able to apply domestic time limits.

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