Irish Revenue on March 15 provided new guidance taxpayers on Ireland’s simplified transfer pricing approach to low-value intra-group services.
The guidance, Tax and Duty Manual Part 35A-01-03, is applicable to situations where a cost-based method is the most appropriate transfer pricing method for determining an arm’s length price among related parties for low-value intra-group services.
Irish Revenue said it is prepared to accept a markup of 5% of the relevant cost base without the need for a benchmarking study.
The guidance applies equally to taxpayers who receive low-value intra-group services from other group members of the same multinational enterprise and to taxpayers who are performing low-value intra-group services for other group members of the same MNE.
The guidance also sets out the documentation requirements taxpayer that avail of this simplified approach for low-value intra-group services.
Be the first to comment