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Transfer pricing (including MAP requests)

  1. Overview
  2. The role of the competent authority
  3. Mutual Agreement Procedures (MAP)
  4. Advance Pricing Agreement (APA)
  5. Article 9 correlative adjustment claims

Overview

Ireland's transfer pricing legislation is set out in Part 35A of the Taxes Consolidation Act (TCA) 1997.

Ireland's transfer pricing legislation applies the arm's length principle. In general, this means that transactions between related parties must be priced as if they were carried out between unrelated parties.

The arm's length principle is to be interpreted in accordance with the OECD transfer pricing guidelines for multinational enterprises and tax administrations.

Next: The role of the competent authority

Published: 10 July 2024 Print this page

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