On 15 March 2018, Irish Revenue has published an eBrief No. 037/18 regarding guidelines on transfer pricing for low value intra-group services.
The purpose of Tax and Duty Manual Part 35A-01-03 is to provide guidance to taxpayers regarding Revenue’s simplified approach to low value intra-group services.
In particular, the guidance outlines that in situations where a cost-based method is determined to be the most appropriate transfer pricing method for determining an arm’s length price for low value intra-group services, Revenue is prepared to accept a mark-up of 5% of the relevant cost base without the need for a benchmarking study.
The guidance also sets out the documentation requirements for the taxpayer in order to avail of this simplified approach for low value intra-group services.
