Ireland Issued Transfer Pricing Manual

Ireland Issued Transfer Pricing Manual

Ireland's Revenue Commission has published the details from its Revenue Operational Manual of how the body should monitor compliance with transfer pricing rules.

The details published refer to provisions enacted into law by the Finance Act 2010, and apply to related-party trading transactions. The Manual states that “if an expense incurred by a trader in dealings with an associated person is greater than the arm's length price, or receipts are less than the arm's length amount, the trader’s profits will be understated for Irish tax purposes."

The monitoring process is focusing on a number of cases of large companies that will be asked to begin a transfer pricing compliance review. After that review an audit may follow, although the Manual stresses that "the taxpayer should understand that Revenue considers the Transfer Pricing Compliance Review program to be a substantial compliance check in its own right and not normally a precursor to the conduct of a transfer pricing audit."

The companies will be asked to provide a report within three months. The report should contain details of group structure, related-party transactions, and pricing structure and transfer pricing methodology. The report also should summarize the functions, assets and risks, contain a summary list of documentation and details of the basis on which arm's length pricing has been determined.

Transactions arranged before July 01, 2010 are named as "grandfathered arrangements," and are allowed to continue provided they meet some requirements. 

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