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The Irish Revenue Commissioners (Revenue) recently published their 2018 annual report together with an analysis of corporation tax receipts for 2016 and 2017 (the Reports).

In a fast-paced business world, with constantly evolving group operational structures and trading relationships, how long does an arrangement really remain unchanged?

Irish Revenue's Annual Report for 2021 (the "2021 Report") highlights a clear increase in mutual agreement procedure ("MAP") activity in Ireland.

In a welcome move, Finance Act 2021 has reformed the existing exemption from transfer pricing for certain domestic transactions. As discussed in our previous update, the application of this exemption had given rise to ...

In a landmark decision, the Irish Tax Appeals Commission ("TAC"), have delivered their determination in the first ever transfer pricing case to be heard in Ireland (59TACD2024).

The Tax Cuts and Jobs Act (TCJA) was enacted in December 2017 to much furore in the US and under the watchful eyes of the international tax community.

The Court of Justice of the European Union has ruled on whether intra-group transfer pricing adjustments constitute consideration for separate supplies of services subject to VAT. While the judgment provides clarity on routine profit margin adjustments, it raises questions about the broader treatment of year-end transfer pricing adjustments and their VAT implications for multinational enterprises.

On 14 September 2023, the Department of Finance published a Roadmap for the Introduction of a Participation Exemption to Irish Corporation Tax.

A recently published determination of the Tax Appeals Commission (TAC), 59 - TACD - 2024, has considered the issue of transfer pricing adjustments in Ireland for the first time.

The Irish Revenue Commissioners ("Revenue") recently published their 2024 Annual Report (the "Report").

As part of its OECD Inclusive Framework on BEPS (IF) commitments, Ireland committed to implement BEPS Action 14 (Making Dispute Resolution Mechanisms More Effective) to resolve treaty-related disputes in a timely, effective and efficient manner.

The European Commission adopted a new package of two proposals for business tax directives in September

The Irish Minister for Finance announced a number of significant Irish property related tax changes on 8 October 2019 in the Irish Budget 2020.

The winds of change that have swept through the international tax landscape in recent years show no signs of abating, and reform remains the order of the day.

At the recent G7 conference, it was announced that a broad agreement had been reached on international tax reform.

A discussion on the taxation of dividends, Irish FATCA compliance, an overhaul to Irish company law, and the recent Irish Budget announcement and Ireland’s implementation of the new Transfer Pricing Regime.

The Irish Finance Bill 2010 (the "Bill") which was recently published proposes the insertion of a new Part 35A into the Taxes Consolidation Act 1997 ("TCA 97") which provides for the introduction of limited transfer pricing ("TP") measures.