Changes to Ireland's Transfer Pricing Regime

09 July 2019

Ireland's transfer pricing regime will significantly change from 1 January 2020 - nine years after its introduction. The government has signaled several areas for potential change, though the details of actual change will only be clear when Finance Bill 2019 is published this November.

From recent discussion with government officials, we now have a stronger understanding of what is likely and what is unlikely to be introduced this year

We have created a brief brochure outlining the known issues that both tax and accounting professionals in Ireland should be informed about including:

-       Adopt 2017 OECD Transfer Pricing Guidelines to set arm’s length prices

-       Introduce documentation standards in-line with OECD Master and Local file framework

-       Remove the grandfathering exemption for arrangements in place before 2010.

-       Remove exemption for small and medium-sized enterprises (SMEs)

-       Extend transfer pricing rules to non-trading and capital transactions

Click Download to find out more about how your company and other technology groups operating in Ireland are likely to respond to these changes.