Transfer pricing (TP) legislation in Ireland has been on the statute books for over a decade; however, a significant overhaul was needed to apply the arm’s-length principle. The main changes were initially brought in by s27 of Finance Act 2019, which substantially expanded and updated the TP legislation by introducing a new Part 35A to the Taxes Consolidation Act 1997 (TCA 1997). The most significant change that this introduced was to create a requirement for businesses with a presence in Ireland (subject to certain conditions) to prepare TP documentation. This obligation applies to chargeable periods commencing on or after 1 January 2020.
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