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Transfer pricing methods

Available methods

Which transfer pricing methods are used in your jurisdiction and what are the pros and cons of each method?

The Irish Transfer Pricing Rules specify neither any particular transfer pricing method nor any preferred one. However, the Irish Transfer Pricing Rules are to be construed in such a way as to ensure, as far as practicable, consistency with the Transfer Pricing Guidelines of the Organisation for Economic Cooperation and Development (OECD).

Preferred methods and restrictions

Is there a hierarchy of preferred methods? Are there explicit limits or restrictions on certain methods?

No. Any transfer pricing method that is applied in compliance with the OECD Transfer Pricing Guidelines will be regarded as acceptable for the purposes of the Irish Transfer Pricing Rules and, where possible, the most appropriate method for the particular type of transaction should be chosen.

Comparability analysis

What rules, standards and best practices should be considered when undertaking a comparability analysis?

The Irish Transfer Pricing Rules do not include specific requirements or guidance in respect of comparability analysis, and Irish Revenue has not published any guidance on the evaluation of comparables. However, as set out above, the Irish Transfer Pricing Rules are to be construed in accordance with the OECD Transfer Pricing Guidelines. Ireland accepts EU comparables, in line with the EU Code of Conduct on Transfer Pricing Documentation.

When seeking to evaluate comparables, Irish Revenue will focus on the commerciality of a transaction and whether it is bona fide in nature.   

Special considerations

Are there any special considerations or issues specific to your jurisdiction that associated parties should bear in mind when selecting transfer pricing methods?


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