Expertise
Ireland Transfer Pricing Firm of the Year
ITR EMEA Tax Awards 2023
Ranked Tier 1
World TP 2025
The team delivers practical, commercial and legally robust pricing advice and solutions to our clients. We provide a unique combination of top-class international tax lawyers working with experienced teams in our corporate, IP, life sciences, IT and banking Groups. With personnel based in Ireland, the UK and the US, the Matheson team offers clients commercially grounded advice, with an internationally informed perspective.
We have advised international companies doing business in Ireland on Irish transfer pricing matters for many years. Typically we advise on:
Documentation
Taxpayers are obliged to retain and have available for inspection sufficient documentation and records to demonstrate the taxpayer’s compliance with the transfer pricing rules. We help clients with all aspects of Irish transfer pricing documentation requirements including key legal documentation underpinning group transfer pricing policies. We also assist multinational clients in complying with the Irish and OECD Country-by-Country reporting obligations.
Strategies and Restructuring
Our transfer pricing team has experience leading international transfer pricing strategies for multinational enterprises (“MNEs”) operating in or from Ireland, including corporate headquarters, sales principals, manufacturers, service centres, R&D centres, and IP holding and exploitation companies.
Our Team
Formal transfer pricing legislation was introduced in Ireland for accounting periods commencing on or after 1 January 2011. However, we have advised international companies doing business in Ireland on Irish transfer pricing matters for many years.
- Matheson advised on the first transfer pricing adjustment completed under Irish law.
- Matheson advised on the first multi-lateral transfer pricing adjustment completed under Irish law.
- Matheson advised on a ground-breaking claim by a non-treaty resident company to correlative relief under an Irish tax treaty.
- Matheson advised on Irish transfer pricing aspects relating to the withdrawal of the judgment of the US Ninth Circuit Court of Appeal in Xilinx v CIR.
The depth of experience of our tax team, combined with our colleagues from practice areas across the firm and our international connections, ensures that Matheson delivers practical, commercial and legally robust transfer pricing advice and solutions to our clients. Our experience includes advising:
- A large technology company on a successful multi-jurisdictional correlative relief claim (one of the first of its kind in Ireland).
- A number of clients on transfer pricing audits and aspect queries from the Irish Revenue Commissioners.
- Clients seeking APAs with the US and other territories.
- On transfer pricing aspects of stand-alone State Aid investigations with our Competition and Litigation colleagues.
- Multinational clients across a number of sectors on Intellectual Property reorganisations involving complex transfer pricing issues.
- A multinational client on the transfer pricing aspects of a complex refinancing and related financial transactions.
- Clients on complying with Country-by-Country reporting obligations, and completing filings with the Irish Revenue Commissioners.
Ireland Transfer Pricing Firm of the Year
ITR EMEA Tax Awards 2023
Ranked Tier 1
World TP 2023