Ireland: Transfer Pricing

The European Commission has adopted a comprehensive Tax Simplification Package aimed at reducing administrative burdens and enhancing competitiveness for businesses operating across the EU. This package consolidates existing tax directives and introduces significant reforms to interest limitation rules, controlled foreign company provisions, and withholding tax exemptions, while establishing new minimum standards for R&D tax treatment to align the EU more closely with major trading partners.

In December each year an annual Finance Act is passed by the Irish Parliament enacting substantive changes to tax law.

The Irish Revenue Commissioners ("Revenue") recently published their 100th Annual Report (the "AR"), a year during which they collected a record amount of tax.