Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 12/3/2012

Ireland - Guidelines for monitoring compliance with transfer pricing law 

December 3: Irish Revenue last week announced a new approach to monitor taxpayer compliance with Irish transfer pricing law (effective in 2011).

According to the guidelines (26 November 2012), the primary mechanism for monitoring Ireland’s transfer pricing regime will be the Transfer Pricing Compliance Review (TPCR) program. In general:


  • A TPCR is a self-review conducted by a company or group of compliance with the Irish transfer pricing law.
  • The review’s goal is to determine whether the arm’s length principle has been correctly applied in relation to relevant trading transactions between associated persons.
  • Companies will be notified by letter from Revenue if they have been selected for a TPCR.
  • The initial focus of the TPCR program will be certain cases selected across a range of large companies.
  • Any company notified that it has been selected for a TPCR will have three months to provide Revenue with a copy of a report that addresses each of a number of issues.

Irish Revenue announced that in situations when a transfer pricing report or study already exists in order to satisfy transfer pricing obligations in another country, that report or study will suffice for the TPCR provided it addresses the issues to be reported to Revenue


Irish Revenue also listed conditions that a company must satisfy if it wishes to rely on the grandfathering provision to exclude transactions, the terms of which were agreed before 1 July 2010, from the scope of the Irish transfer pricing rules.


Read a November 2012 report [PDF 81 KB] prepared by the KPMG member firm in Ireland: Irish Transfer Pricing Compliance Reviews




Contact a tax professional with KPMG's Global Transfer Pricing Services.




©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to go-fmtaxnewsflash@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now

Contact us