On 7 May 2026 the Irish Revenue Commissioners (“Revenue”) published their Annual Report for 2025 (the “Report”), together with supporting research and statistical papers. The Report provides a comprehensive review of Revenue’s activities over the previous year and plays a central role in informing trend patterns for future years. In this insight, we examine the key findings from the Report with a focus on international tax matters and Revenue’s strategic priorities.
APAs and MAPs
The Report highlights Revenue’s ongoing commitment to resolving international transfer pricing disputes through Mutual Agreement Procedures (“MAP”) and the growing demand for proactive transfer pricing certainty through Revenue’s Advance Pricing Agreement (“APA”) programme. The Report highlights the following key statistics for 2025:
- 54 MAPs were completed during 2025, including 22 transfer pricing cases;
- 73 MAPs were initiated, which included 41 transfer pricing cases;
- 12 APAs were concluded during 2025;
- 13 new APA requests were received, which brought the total year-end APA inventory to 76; and
- Two APAs were rejected and a further three were withdrawn by the taxpayer.
These statistics highlight the increasing popularity of the MAP and APA programmes. MAP is more frequently seen by taxpayers as an effective mechanism for resolving double tax disputes and the Irish Competent Authority has a strong reputation for constructive and effective engagement in MAP cases.
In October 2025, Ireland received an OECD award for “Advance Pricing Agreement Most Improved Jurisdiction” in recognition of the significant increase in APAs agreed in 2024 compared to 2023. This upward trajectory has continued, with APAs concluded increasing from one in 2023 to 10 in 2024 and to 12 in 2025. This marks the highest number of APAs completed by the Irish Competent Authority in any year to date.
Exchange of information
Revenue has a wide range of statutory provisions and international agreements in place to facilitate the exchange of information (“EOI“) with other tax administrations. In 2025, Revenue continued to negotiate, agree, and implement new EOI initiatives. The Report highlighted the following key EOI activities:
- In line with EU/OECD transparency on tax rulings, Revenue shared details of 30 opinions (which were foreseeably relevant to other EU Member States) with other jurisdictions;
- Revenue exchanged Country-by-Country (CbC) data with 71 other jurisdictions, informing high level transfer pricing risk assessments and other BEPS-related risks;
- Revenue received 2,802 requests for information from EU Member States and other countries, and made 524 requests through the Mutual Assistance Programme; and
- DAC9, the EU mechanism for the automatic exchange of Pillar Two top-up tax information was negotiated and agreed in 2025. Ireland signed the GloBE Information Return Multilateral Competent Authority Agreement in July 2025 and lodged notification with the OECD to activate the exchange in December, with technical work underway ahead of the December 2026 deadline for initial exchanges.
Future focus areas
The Report signalled future focus areas of Revenue, including:
- Pillar 2 readiness: The first Pillar Two top-up tax returns are due in June 2026, and in preparation, Revenue advanced a number of key operational developments during 2025. This progress includes deploying systems for registration, ongoing support and guidance for large MNEs and preparing for related international information exchange.
- Use of AI: Looking ahead, the Report highlighted Revenue’s openness in deploying new technology in order to improve efficiencies. The Report noted that Revenue will continue to utilise advances in technology, including AI, to automate certain internal processes for screening and flagging issues across tax cases.
Key takeaways
The Report highlights that transfer pricing remains a key focus for audit and compliance activity. Amidst the audit activity, we also see that taxpayers are seeking proactive certainty to prevent tax disputes. This is evident in the 76 ongoing APA cases as at the end of 2025. The highest number of APAs concluded in a year to date (12) reflects the increased resources and experience of the Irish Competent Authority team and signals the popularity of the APA programme with taxpayers in Ireland.
More broadly, the Report notes that Revenue are strengthening their own framework to ensure their readiness for the upcoming Pillar 2 filings. This is expected to result in a new area of audit and compliance focus for future years.
This article is the first of a two-part series. The next article will examine the compliance-related aspects of the Report.
Contact us
Matheson’s tax team can assist multinational enterprises and large businesses with managing complex domestic and international disputes, navigating APA and MAP processes, and preparing for Pillar 2 readiness.
Should you have any questions on the Report, please reach out to any member of our Tax team or your usual Matheson contact.