Ireland updates transfer pricing guidance

On February 24, 2021, Irish Revenue issued Revenue eBrief No. 037/21, stating that 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 January 1, 2020, and, in relation to the computation of certain capital allowances where the related capital expenditure is incurred on or after January 1, 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 January 1, 2020. For chargeable periods commencing on or after January 1, 2020, the documentation requirements are outlined in Tax and Duty Manual Part 35A-01-01.
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See Revenue eBrief No. 037/21