The Irish transfer pricing regime provides for arm’s length pricing to apply to intra-group transactions, using the Organisation for Economic Co-operation and Development (OECD) principles.
Transfer pricing legislation has become increasingly complex. At the same time, multinational corporations are facing greater scrutiny of their tax affairs by all stakeholders. The OECD’s Base Erosion and Profit Shifting (BEPS) agenda has also significantly impacted transfer pricing policies.
At Grant Thornton, our transfer pricing team can help your organisation remain compliant with existing and evolving tax regulations while providing solutions tailored to meet your individual business needs.
Our Transfer Pricing Services
Our transfer pricing team advises and supports companies with their Irish transfer pricing compliance obligations. Our services include:
- Preparation of transfer pricing documentation that is comprehensive, accurate and compliant with local and international legislation and adheres to the arm's length principle.
- Review of existing transfer pricing documentation to ensure that it is up to date and complies with statutory obligations and the arm’s length principle.
- Economic analysis of current or potential structural models that reflects business and market conditions to help minimise the risk of disputes with tax authorities.
- Develop planning documentation that considers commercial reality and is consistent with the arm's length principle.
Navigating Ireland’s complex transfer pricing rules can be challenging for both Irish inbound and outbound companies. Our transfer pricing team will provide guidance and support to make informed decisions aligned with the Irish legislation. Our services include:
- Developing transfer pricing policies that satisfy the specific needs of our clients’ organisation(s) and local and international legislation. Our strategic advice will assist you in structuring your intercompany transactions for optimal transfer pricing outcomes while minimising the risk of errors.
- Intellectual property modelling to optimise your intellectual property strategy and business operations while ensuring compliance with transfer pricing regulations. This modelling includes an analysis of IP assets, risks and opportunities and the development of a tailored strategy that maximises value.
- Business modelling and restructuring to optimise your business operations and structure while ensuring compliance with transfer pricing regulations.
- Risk assessments to identify potential transfer pricing risks and make practical recommendations to mitigate them. We use a range of tools and approaches to assess whether transactions are compliant with the arm's length principle and provide solutions that are mindful of business needs.
- Financial Services tailored transfer pricing solutions that comply with both local and international legislation.
Our transfer pricing team has extensive experience previously working in HMRC and other tax professional firms, and they are equipped to prevent and resolve disputes with tax authorities. The team’s proactive advice minimises the risk of disputes while offering tailored dispute resolution services.
Our services include:
- Risk assessments that identify potential transfer pricing risks as a part of assessing your business’s existing tax risk framework. Practical recommendations for mitigating any issues arising out of transfer pricing positions taken.
- Defence documentation designed to ensure that the transfer pricing arrangements are compliant with local regulations and reflect actual business operations.
- Compliance review assistance to guide and support the company through a transfer pricing compliance review. Our team will work closely with you to ensure that your submissions and responses, including documentation, are comprehensive and up to date thereby reducing exposure to potential transfer pricing adjustments including interest and penalties.
- Managing intervention and audit responses with the expertise and support needed to navigate through the investigation process effectively.
- Assistance with dispute avoidance/ resolution mechanisms such as Advance Rulings, Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs), and more.
Our operational transfer pricing services are designed to provide businesses with expert guidance and support to optimise transfer pricing arrangements. Our transfer pricing team will work collaboratively with you to provide practical solutions that meet your needs while ensuring that transfer pricing policies are compliant with local and international legislation. Along with the documentation services that form a crucial base for tax risk framework, our services include:
- Collaborative workshops and training to provide relevant personnel with the knowledge and tools to have a thorough ability to identity and address potential transfer pricing issues and ensure successful implementation of transfer pricing arrangements within multinational groups.
- Value chain analysis and business model optimisation to identify potential transfer pricing risks and provide recommendations for mitigating them. The transfer pricing team helps businesses understand how to optimise cross-border operations and provides practical solutions to enhance transfer pricing arrangements. Our bespoke solutions will ensure that the business remains competitive and the business models are transfer pricing compliant.
- Agreements review from a transfer pricing perspective to ensure that they comply with the Irish legislation and reflect actual business operations so that transfer pricing arrangements are consistent in both documentation and in practice.
- Recording transfer pricing related outcomes in the books and records of the business. The transfer pricing team will ensure that the business’s financial statements accurately reflect transfer pricing arrangements, ensuring compliance and minimising risk.
- Group transfer pricing manual outlining the intercompany arrangements and corresponding transfer pricing policies. This document forms a critical part of your tax risk framework and serves as an internal transfer pricing reference manual. The team collaborates to ensure that the transfer pricing manual meets the specific business needs and accurately reflects the business operations and transfer pricing arrangements.
- Transfer pricing policy implementation assistance to ensure that company policies are integrated into the business operations and aligned with the business objectives.
- Transfer pricing framework development as part of the overall group tax risk management framework. The transfer pricing team tailors the company’s framework to the specific needs while satisfying both local and international legislation.
Why Grant Thornton
The Irish Transfer Pricing team has extensive experience across all industries including pharmaceuticals, financial services, automotive, engineering, food and agriculture, technology media and telecommunication (TMT). The team is positioned to assist clients overcome increasingly refined challenges, and deliver sector-specific, relevant and sustainable Transfer Pricing solutions to meet increasingly stringent legislation. The team work with clients to develop comprehensive transfer pricing policies and procedures to suit their organisation.
Our Irish team works closely with the global Grant Thornton network of Transfer Pricing specialists to deliver consistent, pragmatic and effective global Transfer Pricing solutions and advice that transcend international borders.
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