Executive summary
On 24 February 2021, the Irish Revenue Commissioners issued a detailed Tax and Duty Manual (TDM) on transfer pricing to provide guidance on the operation of transfer pricing rules as set out in Part 35A of the Taxes Consolation Act, as updated by Finance Act 2019. This legislation applies to companies with accounting periods commencing on or after 1 January 2020, or to capital transactions which occurred on or after that same date. Although transfer pricing legislation was intro…