Preview of Finance Bill 2019 - Transfer Pricing

18 September 2019

Ireland's transfer pricing and international tax regime will dramatically change from 1 January 2020. The Department of Finance released a Feedback Statement on 2 September, containing proposed legislation that adopts latest international standards for corporate taxation in Ireland.

The Irish government is making fundamental changes to transfer pricing laws to reflect new global standards set by the OECD. The proposed legislation, however, addresses international tax and transfer pricing matters broader than what has been advocated in the OECD agenda.

Finance’s proposed legislation covers eight general areas:

1)    2017 OECD Transfer Pricing Guidelines

2)    Documentation using Master and Local Files

3)    Re-characterize arrangements lacking substance

4)    Excessive payments deemed a distribution

5)    Remove exemption for medium-sized companies

6)    Remove Grandfathering exemption

7)    Apply transfer pricing to specified non-trading transactions

8)    Extend rules to capital transactions

DOWNLOAD our brochure to find out more about the proposed legislation, the government’s objectives and the impact to Irish business.