Revenue eBrief No. 231/22 – Guidance on Part 35A Transfer Pricing


Revenue eBrief No. 231/22

23 December 2022

Guidance on Part 35A Transfer Pricing

Tax and Duty Manual Part 35A-01-01 – Transfer Pricing – has been updated for the following amendments to the transfer pricing rules in Part 35A of the Taxes Consolidation Act 1997:

  • Finance Act 2021 substituted section 835E of the Taxes Consolidation Act 1997, which provides for an exclusion from the application of transfer pricing rules in certain circumstances.
  • Finance Act 2022 updated the definition of ‘transfer pricing guidelines’ in section 835D of the Taxes Consolidation Act 1997. It now refers to the updated OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published by the OECD on 20 January 2022.

The Tax and Duty Manual has also been updated to reflect the Code of Practice for Revenue Compliance Interventions which came into effect on 1 May 2022.

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