Ireland releases new bilateral APA manual

June 23, 2016 − by mgpartners − in News − Comments Off on Ireland releases new bilateral APA manual

Irish Revenue have just released their new bilateral APA manual.  These are the only APAs which Irish Revenue have a legal basis for agreeing.  Generally taxpayers must self-assess their transfer pricing until subject to a tax audit.

It must be borne in mind that with current EU Commission State Aid challenges, Revenue are being more careful to ensure that their actions remain intra vires than they may have been in the past.  This has had a knock on effect in terms of them resisting giving advance rulings on the correct application of Irish tax law.





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