Friday, 29 July 2016

Ireland introduces formal bilateral APA program

The Irish Revenue Commissioners have introduced a formal bilateral advance pricing agreement (APA) program which will be effective from July 1, 2016. Prior to this, Ireland accepted requests for bilateral APAs with treaty partners where invited to do so by the other country. The new program was introduced in response to Action 14 of the Base Erosion and Profit Shifting (BEPS) initiative with a view to providing certainty to taxpayers in relation to the taxation of cross-border transactions and is in line with OECD Best Practice Guidelines.

An Operational Manual has been issued by Irish Revenue which outlines the APA framework, governance, process, roles, responsibilities, and mutual expectations for taxpayers and the Irish authorities in applying for, negotiating, and concluding bilateral APAs.

Source & more info: PwC