111 results found

The primary Irish transfer pricing legislation is contained in Part 35A of the Taxes Consolidation Act 1997 (the ''TCA'') which applies to accounting periods commencing on or after January 1, 2011...

The Irish tax rules are found in a group of statutes that have been enacted by the Irish Parliament (the Oireachtas).

The OECD recently published its Stage 2 MAP Peer Review Report for Ireland on the implementation of BEPS Action 14.

The work of the OECD, the EU State aid investigations, public perception and the hunt for public funds by various Governments...

This new development relates to a proposal to make country-by-country financial and tax information of certain multinational groups or standalone entities publicly available.

In recent years, the U.S. Tax Court has been at the center of high-stakes transfer pricing disputes involving multinational corporations and the Internal Revenue Service. Two of the most consequential cases—Facebook, Inc. v. Commissioner and Medtronic...

On 29 January 2024 the OECD released its first aggregated results and statistics for the International Compliance Assurance Programme ("ICAP") (the "Statistics"). 

The Irish Revenue Commissioners ("Revenue") published updated transfer pricing guidance in February 2021 (the "Guidance"), which includes an overview on the enhanced transfer pricing documentation...

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

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 Irish Revenue Commissioners ("Revenue") recently confirmed that Ireland's spontaneous exchange of information regime will apply to certain tax rulings issued as far back as 1 January 2010...

The European Commission's Tax Simplification Omnibus proposes sweeping changes to EU direct tax rules, including the elimination of withholding taxes on intra-EU payments and controversial carve-outs from CFC rules for Pillar Two groups. While promising significant compliance relief for multinational enterprises, the proposals face political headwinds from Member States concerned about revenue impacts and misalignment with OECD standards.

Businesses in Ireland tend to incorporate in order to take advantage of the benefits of separate legal entity status and limitation of liability.

Ireland is a leading European jurisdiction for the establishment of bond-issuing special purpose vehicles ("SPVs"), securitisation companies.

The Irish Revenue Commissioners are increasingly exercising their statutory powers to compel taxpayers to produce documents and information, both for domestic tax enquiries and in response to exchange of information requests from foreign tax administrations. A recent UK First-Tier Tribunal decision in Lifeplus Europe Ltd v HMRC provides valuable guidance on the scope and limits of these information-gathering powers, particularly regarding the concepts of 'reasonably required' and 'possession or power' in th

Ireland's transfer pricing rules were significantly overhauled with effect from 1 January 2020. The Irish Revenue Commissioners published new guidance on the application of these rules in February 2021.

The annual Irish Budget provides a platform for the Irish Minister for Finance to announce tax changes and also to take stock of Ireland's economy and strategy for future growth.