Transfer pricing rules for transactions involving low-tax countries : Ireland

Part of a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective. This article discusses Irish tax legislation and case law relevant to transfer pricing, particularly with regard to transactions between Irish tax residents and tax haven residents, as well as specific measures taken by the European Union and the OECD to encourage the exchange of information between countries. In addition, Ireland's reaction to the introduction of e-commerce and the growing tendency to apply shared service concepts within multinational enterprises are also considered.