On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 – Requests for Transfer Pricing (TP) Documentation.
This Tax and Duty Manual documents the operational policy of the Transfer Pricing Audit Branches of Large Corporates Division for requesting transfer pricing documentation from taxpayers as part of the risk appraisal process.
This manual also provides a forum for requesting transfer pricing documentation under the Compliance Intervention Framework, as set out in the Code of Practice for Revenue Compliance Interventions.
