Irish Revenue published their 2024 Annual Report on 30 April 2025, which included useful updates on transfer pricing compliance and progress made by the Irish Competent Authority in respect of MAPs and APAs.

Irish Competent Authority

The TP Branch of Revenue’s International Tax Division acts as Competent Authority in respect of TP related MAPs and is responsible for Ireland’s Bilateral APA programme. 

As illustrated below, there were 31 TP MAPs initiated and 24 TP MAPs completed with Competent Authorities in other jurisdictions in 2024. Further statistics on the average time to complete MAPs will be published by the OECD towards the end of this calendar year. For context, the average time to close a transfer pricing MAP involving Ireland in 2023 was 31.50 months (just lower than the OECD average in 2023). 

Table 1: Mutual Agreement Procedure Statistics

In addition, Ireland received 23 new APA requests with treaty partners during the year. 10 APAs were concluded in 2024, representing a substantial improvement in the number of APAs concluded year on year (with only 1 APA concluded in 2023). Nevertheless, the continued growth in Ireland’s APA inventory is part of a broader international trend of lengthier processes required to reach completion. The annual filing of APA statistics by OECD countries (published for the first time in respect of 2023) will likely place an increased focus on reducing APA completion times over time.     

Table 2: Advance Pricing Agreements Statistics

The increase in year-on-year closing inventories for MAPs and APAs indicates that TP related disputes involving Ireland remains prevalent. It also illustrates the importance of continued investment and resourcing of the Irish Competent Authority.

Domestic TP Compliance and Audit Activity

Irish Revenue have two Principal Officer led TP audit branches in the Large Corporates Division responsible for risk-based TP audits and compliance interventions nationwide. Other Revenue branches of the Large Corporates Divisions and the Medium Enterprises Division can and do also open interventions which feature transfer pricing issues.

In 2024, 13 TP interventions were closed, yielding €40 million and accounting for circa 7% of the total compliance yield from all Revenue interventions closed in the year. Although there has been a slight decline in TP yield in 2024 compared to previous years, an increase in the tax value of losses restricted of €16m (i.e., €128m of losses denied) shows that Irish TP audit teams have frequently identified TP risks in Irish loss-making entities, denying the potential for loss relief in future periods. The closure of 13 interventions has resulted in a reduction of the closing inventory of TP audits for the first time and suggests that there will be increased capacity for new cases in 2025.

The table below provides a more detailed breakdown of yearly results since 2015 based on information provided in Revenue Annual Reports from 2019-2024.

Table 3: TP Audits and Other TP Compliance Interventions (2015-2024)

Training/Resourcing in Transfer Pricing

In 2024, 41 staff members from the International Tax and Large Corporates Divisions completed external training courses on intellectual property valuation and transfer pricing. This represents a substantial investment in the development of transfer pricing expertise and is indicative of the increased complexity of transfer pricing issues encountered by Irish Revenue.  

Deloitte Ireland LLP
May 2025