Transfer Pricing

The Transfer Pricing 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:

Audits and Litigation
Mutual Agreement Procedures and Correlative Adjustment
Advance Pricing Agreements
Documentation
Strategies and Restructuring

Experience Highlights

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.

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.