The minister in his Budget speech reiterated previous commitments to undertake a review of Ireland’s transfer pricing (TP) regime during 2019. Any changes arising from the review will likely take effect from 1 January 2020. The changes will include formally adopting the OECD’s 2017 TP Guidelines - Ireland currently applies the OECD 2010 TP guidelines under domestic legislation.
The public consultation will give further consideration to a number of TP matters including:
]There is a commitment from policy makers that any changes will be made in a careful, considered manner as one coherent package.
Reform of the Irish transfer pricing rules could have a significant impact on taxpayers.
Transfer pricing is without doubt the single biggest area of potential dispute and source of controversy for many taxpayers. The revision and clarification of OECD transfer pricing principles in certain key areas has been at the very core of international tax changes. It is clear the reform of Ireland’s transfer pricing regime will significantly impact upon Irish based businesses.