Transfer pricing

Transfer pricing relates to all aspects of intra-group pricing arrangements between related business entities. The transfer pricing policies of MNC’s have recently attracted a high level of international attention, due in part to the rapid rise of multinational trade, the opening of several developing economies and the increased impact of transfer pricing on corporate income taxation.

In Ireland, transfer pricing rules apply to a wide range of related party transactions, including those between two Irish companies. In principle, the rules cover almost everything from sales or purchases of goods and services to intellectual property and financing transactions.

Potential issues

  • Setting and implementing a robust and defendable transfer pricing policy that complies with the arm’s length principle
  • Evidencing and supporting compliance with transfer pricing regulations, including documentation requirements, both in Ireland and abroad
  • Managing transfer prices and head office/ branch attributions accurately within your group across many jurisdictions
  • Designing intra-group business models to achieve sustainable financial and operational benefits
  • Determining how shared services between departments can help control costs, optimise your processes, and create visibility throughout your business’ value chain
  • Defending and managing challenges from tax authorities internationally
  • Increasing scrutiny from tax authorities on the pricing of intra-group financial transactions and supporting such financial transactions in this environment
  • Understanding what impact the OECD’s Base Erosion and Profit Shifting (BEPS) action plan will have on your business

How can we help?

With over 3,000 transfer pricing professionals, across 80 countries, we are the world’s leading adviser* for transfer pricing.

Our transfer pricing team in Ireland has extensive experience in leading and coordinating international projects to develop and implement intra-group transfer pricing models, to assist with dispute resolution and to prepare transfer pricing documentation across all industries, including financial services where we have dedicated transfer pricing specialists in the following sectors: insurance, asset management, banking & capital markets and aircraft leasing.

We can help with the following:

  • Managing your transfer pricing requirements from policy setting and documentation to implementation and integration within your business structure
  • Developing and implementing sustainable intra-group business models that allocate profit appropriately across the group and realise intra-group optimisation of intellectual property
  • Providing health checks to identify risks, gaps or opportunities in your transfer pricing procedures
  • International dispute resolution - in the event of a transfer pricing dispute, we can help you to manage and defend a tax authority enquiry
  • Providing pragmatic valuable guidance on the full range of intra-group financial transactions and the unique transfer pricing issues that the financial services industry faces
  • BEPS related strategic risk assessments
  • Leveraging our global presence to develop a compliant, tax-efficient structure covering all of your business locations

*The Global Tax Monitor recognises PwC as the leading adviser globally and in Ireland for transfer pricing, by reputation, with a very strong lead over the competition. These results are based on the year-ending Q4 2013 figures, with a sample size of 4,060 primary buyers of tax services globally.