Transfer Pricing Express 

An Irish focus on the key global transfer pricing developments facing companies. 

Transfer Pricing Express is our quarterly update of key transfer pricing issues that companies operating in Ireland face in an ever changing tax environment. Each edition will focus on some of the Irish and global transfer pricing related developments that companies need to be aware of.


Our third edition of Transfer Pricing Express outlines some of the key transfer pricing developments in Ireland and further afield that Irish companies need to be aware of.

 Our current edition includes the following:

  • Transfer pricing developments in Ireland during 2017 to date: Including the impact for Ireland on the publication of the 2017 OECD Transfer Pricing Guidelines, discussion on various guidelines published by Irish Revenue year to date and Ireland’s position on the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”).
  • OECD update: Discussion on a number of publications and discussion drafts issued by the OECD of relevance from a transfer pricing perspective in 2017 to date including the updated Transfer Pricing Guidelines which replace the 2010 version, discussion drafts relating to a number of the BEPS final papers, further guidance notes issued pertaining to country-by-country reporting and the multilateral instrument for implementing BEPS in tax treaties.
  • EU Update: Details relating to public country-by-country reporting, APA statistics issued for 2015 and the publication of two transfer pricing studies by the EU in the period.
  • Country Focus - Luxembourg: Our final article discusses the significant changes to Luxembourg’s transfer pricing law in relation to intragroup financial transactions which are effective from the start of 2017
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Our special year end edition of Transfer Pricing Express outlines some of the key transfer pricing considerations that companies need to be aware of at the end of the financial year.  

In this edition, we discuss the following issues:

  • Competent authority notifications: Where companies intend seeking relief from double taxation under a tax treaty, it is important to understand that in certain circumstances, there are specified deadlines set out in many of Ireland’s tax treaties, to notify the Irish and foreign tax authorities to protect the taxpayer’s right to access treaties dispute resolution mechanisms. 
  • Country-by-Country Reporting Notification Deadlines: Whilst the filing of the first reports will take place in 2017, many jurisdictions require notification to be made before the end of 2016 regarding which entity will be filing the Country-by-Country Reports and details of local constituent entities. 
  • Year-End Transfer Pricing Actions: Annual review of operation of transfer prices is critical for companies and actions required to be taken before the end of the year to ensure compliance with arm’s length pricing. 
  • Grandfathering under Ireland’s Transfer Pricing Regime: Still relying on grandfathering under Ireland’s domestic transfer pricing regime?  You may want to review the position again in light of changes in the business since transactions were entered into between related parties. 
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Our first edition of Transfer Pricing Express outlines key transfer pricing developments impacting Irish businesses – both Irish and key global developments. 

Our Winter 2016 edition includes the following: 

  • Ireland: Developments in 2016 to date including BEPS changes such as Country-by-Country Reporting and introduction of a new bilateral advance pricing agreement (APA) regime.
  • OECD: Key transfer pricing related developments in 2016 to date.
  • Masterfile & Local File Implementation Update: The new transfer pricing documentation challenges facing companies.
  • Section 110 changes in Ireland: Recent legislative changes and transfer pricing impact. 
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