Irish Revenue Annual Report 2025: Transfer Pricing highlights
Irish Revenue published their 2025 Annual Report on 7 May 2026, 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 41 TP MAPs initiated and 22 TP MAPs completed with Competent Authorities in other jurisdictions in 2025, leading to a further increase in the TP MAP inventory (at 116 cases). 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 2024 was 35.57 months.
Table 1: Mutual Agreement Procedure Statistics
In addition to TP MAPs, Irish Revenue also resolve other non-transfer pricing disputes (“other MAPs”), which address matters such as withholding tax and permanent establishment (“PE”) issues. During 2025, Irish Revenue resolved 32 cases which related to other double taxation disputes. Recent years have seen a noticeable uptick in foreign tax authority challenges asserting withholding tax and PE positions and it will be interesting to monitor whether "other MAPs" cases increase in future reporting period and/or are resolved to avoid double tax.
Furthermore, Ireland received 13 new APA requests with treaty partners during the year. 12 APAs were concluded in 2025, representing a continued improvement in the number of APAs concluded year on year (with 10 APAs concluded in 2024 and only 1 APA concluded in 2023). In October 2025, Ireland received an award from the OECD in respect of the “Advance Pricing Agreement Most Improved Jurisdiction”, in recognition of the increase in APAs granted in 2024 compared to 2023.
Table 2: Advance Pricing Agreements Statistics
Irish Revenue continue to advocate for Ireland’s APA programme to achieve certainty for taxpayers and cite the benefit of the forward looking nature of such negotiations (versus backward looking MAP processes where assessments are already raised). Interestingly, in 2025, 2 APAs were rejected and 3 withdrawn by taxpayers – perhaps the first signs that entry to the APA programme is no longer guaranteed.
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 2025, 9 TP interventions were closed, yielding €35 million and accounting for circa 5% of the total compliance yield from all Revenue interventions closed in the year. The reduction of the closing inventory of TP audits during the last two years suggests that there will be increased capacity for new cases and Revenue cite, in the annual report, their increased use of L1 interventions focused on TP documentation obligations.
The table below provides a more detailed breakdown of yearly results since 2015 based on information provided in Revenue Annual Reports from 2019-2025.
Table 3: TP Audits and Other TP Compliance Interventions (2015-2025)
Exchange of Information
Revenue has a range of statutory provisions and international agreements in place to facilitate the exchange of information with other tax administrations. In 2025, Revenue exchanged Country-by-Country (CbC) data with 71 other jurisdictions, informing high-level transfer pricing risk assessments and other BEPS-related risks. Irish Revenue also received 2,802 exchange of information requests from other tax authorities, whilst making 524 such requests in 2025.
Deloitte Ireland LLP
May 2026
