Revenue eBrief No. 037/21
24 February 2021
Guidance on Part 35A Transfer Pricing
Tax and Duty Manual Part 35A-01-01 - Transfer Pricing - has been updated to provide guidance on the operation of the transfer pricing rules in Part 35A Taxes Consolidation Act 1997 as updated by Finance Act 2019. Part 35A of the Taxes Consolidation Act 1997, as substituted by Finance Act 2019, applies for chargeable periods commencing on or after 1 January 2020 and, in relation to the computation of certain capital allowances where the related capital expenditure is incurred on or after 1 January 2020.
Tax and Duty Manual Part 35A-01-02 - Transfer Pricing Documentation Obligations - has also been updated to reflect that it does not apply for chargeable periods commencing on or after 1 January 2020. For chargeable periods commencing on or after 1 January 2020, the documentation requirements are outlined in Tax and Duty Manual Part 35A-01-01.