Transfer Pricing
Budget 2027
Key measures for transfer pricing
Technical changes relating to transfer pricing are normally the purview of legislative updates such as the Finance Bill. Whilst there have been no specific measures announced in Budget 2027 relating to transfer pricing, there have been many important measures and announcements globally which are of relevance to Irish taxpayers.
In June 2026, the OECD issued a draft revision to Chapter VII of the OECD Transfer Pricing Guidelines (“TPG”) which deals with intragroup services. The discussion draft further develops the existing guidance in line with the basic principles of Chapter I and II of the TPG and places a stronger focus on the accurate delineation of transactions and seeks to provide more clarity with regard to the benefit test as well as providing more guidance on the distinction between genuine services and shareholder services. A key new inclusion relates to documentation recommendations for intragroup services which is intended to supplement the existing guidance on documentation contained within Chapter V of the TPG. Taxpayers may be expected to collate evidence considered as "useful and relevant" for the pricing of intragroup services such as descriptions of processes chosen to allocate costs, justifications for selected allocation keys, explanations and calculations of how cost bases were constructed, breakdowns of pass-through costs and invoices from external service providers. A further public consultation is planned for November 2026 with final guidance expected in 2027.
During 2026, the OECD continued with Pillar 2 implementation with the publication of the Side-by-Side Package in January which introduced safe harbours to reduce the compliance burden for effected taxpayers as well as publication of guidance in April and September. The first filing and payment deadline for impacted taxpayers in Ireland was 30 June 2026 for 31 December 2025 year-ends. Budget 2027 announced that amendments will be made in the Finance Bill to give effect to the provisions of the Side-By-Side Package agreed earlier this year.
Under Irish rules implementing Directive (EU) 2021/2101 relating to public country-by-country reporting ("EU PCbCR"), many impacted Irish companies and branches have commenced publishing their first reports this year. The Irish rules apply to financial years beginning on or after 22 June 2024, and the report must be made publicly available within 12 months of the balance sheet date. For in-scope companies with a 31 December year-end, first reports are expected to be published by 31 December 2026. For impacted large domestic and foreign-owned MNEs, dealing with the new compliance obligation has been challenging due to the divergence across the EU in the transposition of the Directive into domestic law.
On the dispute front, transfer pricing tax controversy continues to be very active in Ireland with a closing inventory of 116 transfer pricing MAP cases and a closing inventory of 76 APA cases at the end of 2025. Transfer pricing audit interventions continue to generate yield for the Exchequer with nine interventions closed in 2025 yielding €35 million and accounting for circa 5% of the total compliance yield from Revenue interventions closed last year.
Explore further details in relation to the latest Irish dispute cases.
Who will be affected?
The myriad of new and updated compliance requirements (transfer pricing documentation and other reporting) that many MNEs are facing continues to be challenging in 2026 to deal with and it is expected that such challenges will continue into next year.
When is this coming in effect and what should we do now?
Regulatory and compliance obligations that taxpayers have to deal with on an ongoing basis are changing all the time and having a defined process with adequate resources to deal with the issues is critical. We continue to observe that taxpayers are seeking to automate compliance workflows and use AI to support compliance needs which will continue to expand going forward.
Deloitte's view on Budget 2027 measures
Over time transfer pricing has shifted from a compliance matter that taxpayers were obliged to deal with to an issue that has become a core component of strategic tax governance. Timely assessment of key transfer pricing issues facing a business together with robust governance processes and careful monitoring is critical more than ever in navigating the dynamic changing environment.
