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In May 2018, Revenue released a briefing which sets out Revenue’s approach to monitoring compliance with transfer pricing legislation contained in the Taxes Consolidation Act 1997 (TCA 1997). It includes background on Revenue’s dedicated transfer pricing audit branch, and guidance on the transfer pricing audit programme, which is now used alongside the Transfer Pricing Compliance Review (TPCR) programme.
What are the practical implications of Revenue's approach for transfer pricing activities, and how should individuals and organisations approach their TP positions accordingly?
First published in Irish Tax Journal in Issue 4 -2018