Irish Revenue announces transfer pricing compliance review (TPCR) guidance

Irish Revenue announces transfer pricing compliance review (TPCR) guidance

On November 26, 2012, the Irish Revenue issued guidance on how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997. A TPCR is a self-review performed by a company of its compliance with Irish transfer pricing legislation. It appears that the TPCR will be an effective approach for Irish Revenue to gather intelligence on the transfer pricing models that companies operating in Ireland have set up. Aside from a TPCR being a potential stepping stone to an audit, exactly how Irish Revenue will use this information remains to be seen. Regardless, Irish Revenue will become better educated and “street smart” on how the arm’s-length principle is employed in practice, with minimum effort in this learning process since the taxpayer will be the teacher.

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