Ireland: Transfer Pricing

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.

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

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.

On 15 November 2023, the OECD published statistics on Mutual Agreement Procedures ("MAPs") and Advance Pricing Agreements ("APAs") and its Competent Authority awards for 2023.

The Finance Bill 2024 was published on 10 October 2024 and, with the likelihood of a general election in November, it is expected that it will progress quickly through...

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

The judicial system in Ireland is established by the Constitution of Ireland, the principal courts being the District Courts and Circuit Courts (with limited jurisdiction)...

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

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