In a recent determination overturning an assessment by the Irish Revenue Commissioners (59TACD2024 — Corporation Tax (taxappeals.ie)), Ireland's Tax Appeals Commission (Commission) ruled that the cost of stock-based awards (SBAs) should be borne by the US parent company, not its Irish subsidiary; as such, the Irish subsidiary did not need to include the SBAs in its cost base for the transfer pricing calculation.
This is the first transfer pricing case decided by the Commission after Ireland's for…