As discussed in our recent article, Ireland's transfer pricing
rules were amended and the scope of their application was
significantly expanded with effect for 2020 onwards. The amendments
have had a particular impact on financial transactions, bringing
many more financial transactions within the ambit of transfer
pricing rules, including documentation requirements. This change
has also coincided with the publication by the OECD of their guidance on the transfer pricing of financial
transactions (the Guidance), resulting in enhanced focus on the
pricing and documentation of these transactions more generally.
The Guidance is significant because it is the first time that
the OECD has provided specific commentary on the application of the
arm's length principle to financial transactions. Businesses
with significant treasury operations will find the latest
commentary particularly relevant. Although the Guidance has not yet
been formally incorporated into Ireland's transfer
