Transfer pricing (including MAP requests)
Article 9 correlative adjustment claims
A correlative adjustment is an adjustment of profits under the terms of a Double Taxation Agreement (DTA) which Ireland has entered into with another country. The purpose of a correlative adjustment is to provide a company with relief from double taxation.
Correlative adjustment cases arise where a company has accepted an adjustment that was raised by a foreign tax administration. The company must have paid the additional tax resulting from the adjustment. Companies resident for treaty purposes in Ireland may seek relief from double taxation arising in such cases. This is done by submitting a claim for a correlative adjustment to Revenue.
Claims for a correlative adjustment must be made using the prescribed Form CA1. The Guidelines for Article 9 Correlative Adjustment Claims contain information in relation to making a correlative adjustment claim.