The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of the APA program, as well as the requirements to apply for an APA, and the roles and responsibilities of taxpayers and Irish Revenue.
The bilateral APA program was launched in response to action 14 of the OECD’s base erosion and profit shifting (BEPS) project. As per the published bilateral advance pricing agreement guidelines, an APA will be granted for a fixed period of time, typically between three and five years. Irish Revenue is willing to consider other fixed periods subject to the other tax administration’s agreement.
