Ireland: Transfer pricing compliance reviews

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Ireland: Transfer pricing compliance reviews

Irish taxpayers will be requested to perform a self-review of their compliance with the Irish transfer pricing rules under a new initiative announced by the Irish Revenue Commissioners.

The self-review process, to be called a transfer pricing compliance review (TPCR), announced on November 26, will require selected taxpayers to provide certain information on their transfer pricing policy to Irish Revenue.

The Irish Revenue is conscious of the compliance burden that can be placed on taxpayers and has helpfully acknowledged that the report provided to them does not have to be in a particular format - a transfer pricing study prepared for the purposes of another jurisdiction may well contain all of the information required by them.

The following information will need to be provided:

(a) the group structure;

(b) details of transactions by type and associated companies involved;

(c) pricing and transfer pricing methodology for each type of transaction;

(d) the functions, assets and risks of parties;

(e) a list of documentation available / reviewed; and

(f) the basis for establishing how the arm’s-length standard is satisfied.

TPCRs will not be formal audits, with the potential for no penalties should an adjustment be agreed during the process. This approach is welcome, and it is an indication of Irish Revenue’s general willingness to engage with Irish taxpayers to discuss their tax policies. It will also provide Irish Revenue with some time to become familiar with the transfer pricing models used by Irish taxpayers in a more co-operative environment and to build their transfer pricing experience.

One of the more interesting aspects of the TPCR is that taxpayers have the opportunity to receive effective sign-off on their transfer pricing methodology and documentation.

If satisfied with the information received in a TPCR report, Irish Revenue will issue a letter confirming that they have no further enquiries in relation to the transfer pricing for that period. Of course, if Irish Revenue is not satisfied with the information received or the transfer pricing adopted, the TPCR process could end by the initiation of a formal transfer pricing audit with the attendant potential for penalties.

The introduction of a process to monitor compliance with the Irish transfer pricing rules was inevitable and the choice of a more informal review process, as the initial contact with taxpayers, is a good starting point.

For the taxpayer, obtaining comfort from Irish Revenue on their transfer pricing policy is an attractive opportunity.

With notifications under the TPCR process set to issue in the coming weeks, Irish taxpayers should be prepared to look in the mirror and examine their compliance with the Irish transfer pricing rules.

By principal correspondents for TPWeek in Ireland, Joe Duffy (joseph.duffy@matheson.com) +353 1 232 2688 and Catherine O’Meara (Catherine.omeara@matheson.com) +353 1 232 2106 of Matheson.

more across site & shared bottom lb ros

More from across our site

Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
All the tax partners elevated across the UK, US and Singapore were private client specialists, continuing a market trend of intense investment and competition
Rolf van de Velde, dubbed ‘an expert chosen by experts’, is tasked with scaling Reptune’s self-service compliance offering
The newly combined firm brings together more than 3,500 practitioners across 52 offices, with flagship hubs in Seattle, London, Sydney and New York.
Building a transparent culture, prioritising internal promotions and being different from the big four are all key features of A&M Tax’s ambitious plans for India
ITR’s Indirect Tax Forum 2026 showed why harmonisation remains elusive, advisers must raise their game, and ‘everyone’s data is rubbish’
The firm’s board has reportedly asked Kevin Burrowes to continue until 2028 as the KPMG Australia scandal raises expectations of regulatory reform
A former Deloitte partner will lead the firm’s latest geographic expansion; in other news, Baker McKenzie added six tax lawyers to its partnership
Gift this article