The Irish revenue authority has announced that it will introduce a formal Advance Pricing Agreement (APA) program and are expected to be published in 2016. Ireland has accepted and concluded bilateral advance pricing agreements (APAs) for many years although there have been no formal measures to initiate an APA in Ireland. However, in light of comments made by an Irish Revenue official at the Global Tax Policy Conference held in Dublin, it appears that such a program in Ireland is imminent.
The Irish Revenue Commissioners accept requests to enter into bilateral APA discussions with bilateral treaty partner countries on a case-by-case basis, in situations where the other country has accepted the APA negotiation request. Generally, these cases are considered complex or are likely to result in a mutual agreement procedure request pursuant to Ireland’s treaty network.
The process is governed by the rules or guidelines of the treaty partner country due to the fact that Ireland does not have any rules in place. Ireland adheres to the OECD and EU published guidance regarding transfer pricing and APAs for all bilateral APA negotiations with treaty partner countries.
