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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.

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.