Transfer pricing (including MAP requests)

Advance Pricing Agreement (APA)

In general, a bilateral APA is a binding agreement between two tax administrations and the taxpayers concerned. This is entered into by reference to the relevant double taxation convention. It governs the treatment for tax purposes of future transactions between associated taxpayers.

Essentially, the APA makes the tax treatment of relevant transactions clear for both the tax administrations and the taxpayers for the period covered.

Effective from 1 July 2016, Revenue introduced a formal bilateral APA programme. The introduction and publication by Revenue of this formal programme provides clarity to taxpayers in respect of both the:

  • process involved in applying for a bilateral APA
  • and
  • ongoing reporting and administrative requirements, once an APA has been agreed.

Guidance on the operation of the programme is contained in Revenue's Bilateral Advance Pricing Agreement Guidelines.

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