Irish Revenue has today released guidelines establishing a formal bilateral advance pricing agreement (APA) program to provide certainty for multinational corporation transfer pricing arrangements.
While Ireland has entered into bilateral APAs in the past, reporting that eight such agreements were in force as of November 2015, the new guidelines formalize the process.
The guidelines, effective July 1, state that the only issues that can be covered by a bilateral APA are transfer pricing issues and the question of attribution of profits to permanent establishments.
APAs will typically last three to five years, though Irish Revenue will consider other fixed periods. Rollback will be permitted and no APA filing fees will apply. In addition, annual reporting requirements will be specified in the APA.
Ireland does not have a unilateral APA program.
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