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ARTICLE · 02 APRIL 2021

Transfer Pricing – Irish Revenue Publish New Transfer Pricing Guidance

Arthur Cox
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Pursuant to Finance Act 2019, a number of changes were made to Ireland's transfer pricing regime which are generally applicable for chargeable periods commencing on or after 1 January 2020 including...

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Fintan Clancy
Fintan Clancy
Ailish Finnerty
Ailish Finnerty
David Kilty
David Kilty
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Pursuant to Finance Act 2019, a number of changes were made to Ireland's transfer pricing regime which are generally applicable for chargeable periods commencing on or after 1 January 2020 including:

  • the extension of the transfer pricing rules to certain non-trading transactions, capital transactions where the market value of the relevant asset exceeds ?25m and previously "grandfathered" transactions;
  • the extension of transfer pricing rules to transactions involving SMEs, on the making of a Ministerial Order;
  • the incorporation of the 2017 OECD Guidelines1 into Irish law;
  • the introduction of an enhanced transfer pricing documentation regime; and
  • the inclusion of a "substance over form" provision which requires taxpayers to disregard and recharacterise a transaction in certain circumstances.

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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