Overview

With Ireland’s attractive corporate tax rates historically drawing a signifi cant level of inbound investment, global and European authorities have been applying increasing pressure for a formal framework to establish Ireland’s principles for pricing of intra-group transactions. Effective from 1 January 2011, and applying to transactions that take place after 1 July 2010, Ireland’s new transfer pricing regulations are dividing opinion, and the rush for grandfathering existing arrangements prior to the July deadline is now on. Any increase in a multinational’s compliance burden only adds to tax directors’ headaches, but with Irish documentation following OECD guidelines, the extension of existing group transfer pricing policy and paperwork to transactions where an Irish entity is a counterparty may be a relatively routine matter.

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