In February 2019, the Finance Department carried out a public consultation on Ireland’s transfer pricing rules indicating the intended direction in respect of certain recommendations contained in the Coffey Review and seeking stakeholders valuable input to the process. The consultation period continued until 2 April 2019. The Department of Finance has published a feedback statement following the public consultation launched in February 2019 regarding amendments to the domestic transfer pricing regime to bring it in line with international best practices developed by the OECD. The closing date for receipt of submissions in response to this document is 13 September 2019. This feedback statement are expected to be added in the upcoming Finance Bill 2019 and effective from 1 January 2020.
The proposed changes are expected to have a significant impact on many businesses that have a related-party arrangement involving Ireland. Following the recommendation in the Coffey review to include specific requirements in Irish transfer pricing legislation for companies to prepare and maintain a Master File and Local File in line with Annex I and II of Chapter V of the 2017 OECD Transfer Pricing Guidelines, the public consultation indicated an intention to introduce enhanced transfer pricing documentation requirements from 1 January 2020. It also provides extension of transfer pricing rules to SMEs.
