Transfer pricing

Transfer pricing relates to all aspects of inter-company pricing arrangements between related business entities, often involving transfers of tangible and intangible property. The use of transfer pricing tax strategies has recently attracted a high level of international attention, due in part to the rapid rise of multinational trade, the opening of several significant developing economies and transfer pricing’s increased impact on corporate income taxation.

In response to these factors, tax authorities around the world have become more aggressive in the transfer pricing arena. And, following the enactment of Finance Bill 2010, we have now entered a new era of regulation and enforcement from an Irish transfer pricing perspective with the introduction of broad based transfer pricing legislation in Ireland.

Research and insights:

• Are you ready to file your corporation tax return?
• International transfer pricing 2012
• Transfer pricing perspectives
• Transfer pricing documentation: Irish developments in a global context with Gavan Ryle.
  (This article was first published in the Irish Tax Review, December 2011)
• PKN alerts
• Global Transfer Pricing website