Transfer pricing (including MAP requests)

The role of the competent authority

A competent authority:

  • is a term used in double taxation conventions
  • is committed to ensuring a good faith application of a double taxation convention
  • will endeavour to resolve issues in accordance with the applicable taxation convention.

In Ireland, Revenue is the competent authority.

You can request competent authority assistance to resolve a dispute arising under a double taxation convention. The competent authority function seeks to resolve international transfer pricing disputes through negotiations with tax authorities of treaty partner jurisdictions.

The report on The Role of the Competent Authority gives an overview of the role of the competent authority in Ireland in resolving international tax disputes.

Next: Mutual Agreement Procedures (MAP)