ARTICLE · 18 JULY 2017

Transfer Pricing Ireland

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Ireland introduced formal transfer pricing legislation for the first time in 2010.

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TRANSFER PRICING: GENERAL OVERVIEW

1. WHAT ARE THE MAIN CHARACTERISTICS OF TRANSFER PRICING LAW AND POLICY IN YOUR JURISDICTION?

Ireland introduced formal transfer pricing legislation for the first time in 2010. The Finance Act 2010 introduced a new transfer pricing regime in Ireland for accounting periods commencing on or after 1 January 2011, for transactions the terms of which were agreed on or after 1 July 2010.

Broadly, the transfer pricing rules require domestic and international transactions between associated persons to be entered into at arm's length. Where an arrangement between associated entities is made otherwise than at arm's length, an adjustment can be made to the Irish company profits. An adjustment is only made where income is understated or expenses are overstated.

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