budget 2022 Transfer Pricing


Transfer Pricing

Budget 2023

There were no specific transfer pricing related measures in Budget 2023, although other tax developments (including Ireland’s commitment to the two-pillar solution and ongoing active engagement with the OECD) will have overarching effects in the transfer pricing landscape in the years to come.

Transfer pricing remains a key focus area for taxpayers, given the increased compliance burden introduced for 2020 onwards as well as the significant increase in transfer pricing audit activity in Ireland. Groups should continue to closely monitor developments and ensure their compliance with the updated transfer pricing rules in Ireland.

Finance Bill 2022: Key Provisions

  • The Finance Bill updates the definition of “transfer pricing guidelines” to require the transfer pricing rules to be construed, as far as practicable, in accordance with the 2022 version of the OECD Transfer Pricing Guidelines. The rules previously referred to the 2017 version of the OECD Transfer Pricing Guidelines. This amendment applies to chargeable periods commencing on or after 1 January 2023.
  • The 2022 version of the OECD Guidelines consolidates into a single publication: the 2017 Guidelines; guidance on the profit split method; application of the approach to hard-to-value intangibles; guidance on financial transactions; and provides clarity on risk free and risk-adjusted returns.


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