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

Death, taxes and Deloitte hoovering up trophies at an ITR awards night. Isn’t that the saying?
AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud
Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
The arrival of Alex Anderson swiftly follows that of funds tax specialist Stuart Alter and suggests the Tier 3-ranked firm has higher ambitions
One of the two appointments is EY’s Gordon McIntosh, who becomes the big four firm’s second senior tax departure in September
Balson's move from a Tier 1 practice to a Tier 3 competitor looks counterintuitive. The market data suggests it is anything but
Awards
It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands
Gift this article