Revenue's annual report 2024: Key transfer pricing takeaways

Every year the Irish Revenue publishes its annual report. This report provides insight into Revenue’s approach to confronting transfer pricing  non-compliance, its efforts to provide tax certainty by way of APAs, and to resolving litigated issues through agreement with other tax authorities under MAPs. 

Revenue’s annual report 2024  was published in April 2025

The following key TP compliance statistics were reported for the period 2015–2024:

• 65 TP compliance interventions were initiated.
• 46 interventions finalised yielding a total of €748mn, including €243mn in interest and penalties.
• Restrictions in trading losses of over €1bn (tax effect: €135mn).
• Amended corporate tax (CT) assessments from TP interventions generated an additional €82m in tax revenue.

A comparison with the 2023 Report indicates that 7 new compliance interventions were initiated and 13 were finalised during 2024 yielding a total €40mn including €10mn in interest and penalties and these interventions restricted losses of over €48mn with tax effect of approx. €16mn. 

In 2023, amended corporation tax assessments with a total underpaid tax of approximately €44 million were raised as a result of transfer pricing compliance interventions. In the 2024 report, this number is €21 million. Although the underpaid tax figure has decreased, that does not necessarily equate to a lower level of activity on the transfer pricing interventions side.

Interestingly, an additional sentence finds its place in the 2024 report mentioning that transfer pricing was a key priority for Revenue in 2024, and confirming that transfer pricing non-compliance will remain a priority going forward. This focus is further emphasised by the fact that 41 staff members from Revenue’s International Tax and Large Corporates Divisions attended external training courses on intellectual property valuation and transfer pricing. 

Similar to the 2023 report, the current report mentions that the majority of amended assessments on account of transfer pricing are currently under appeal. Around this time last year the first Irish transfer pricing case was decided by the Irish Tax Appeals Commission (TAC). It will be interesting to observe these new cases and understand the issues litigated, arguments put forward by both Revenue and taxpayers, the verdicts given by the TAC, and associated TP implications. 

According to Revenue’s 2024 Report, notable updates on TP cases under MAP and APA were as follows:

MAP Cases: During 2023, Revenue completed 24 MAP cases (as per Annual Report 2023, it completed 16, that means this year it completed 50% more than last year) and initiated 31 additional cases, bringing the total MAP inventory to 98 by the end of 2023.

APAs: The opening inventory of APA applications under consideration at 1 January 2024 was 68.  During 2024, Revenue received 23 new applications and it concluded 10 APAs (a fantastic jump from 1 conclusion in year 2023).  Similar to year 2023, in 2024 one of the taxpayers withdrew their APA application and the final inventory awaiting resolution at 2024 year ended tallied at 80.

The above figures pertaining to completion of MAP cases and APAs show considerable efforts by Revenue in TP dispute resolution and avoidance.

An interesting observation from the report highlights that Revenue exchanged CbCR data with 72 jurisdictions (that is 10 more jurisdictions than in 2023). This data included details on revenue, profits, taxes paid, and other economic activity indicators of large multinational enterprises (MNEs). Revenue stated that it leverages this information to conduct high-level TP risk assessments and evaluate risks related to base erosion and profit shifting.

Ireland’s TP landscape is set to become increasingly dynamic, driven by a substance-focused economic model that attracts significant foreign direct investment (FDI). While Ireland’s tax authorities may not adopt the aggressive stance seen in some developing countries, they are expected to maintain a strong framework to defend the tax base and enforce compliance with arm’s length pricing. A strong TP audit framework will likely be central to this strategy.

Revenue will likely focus on following key issues, making them a priority for taxpayers:

• Debt capacity of Irish borrowers and cross-border financing transactions.
• Justification of losses for Irish subsidiaries engaged in high-end R&D for group entities.
• Global value chains, particularly DEMPE functions in Ireland.
• Management cost recharges and the benefit test.
• Persistent losses in low-risk entities.
• Changes to TP models and business restructurings.

Best practices for MNEs:

• Maintain comprehensive documentation with thorough functional, comparability, and economic analyses demonstrating compliance with the arm’s length principle.
• Engage experts to provide objective analyses and testimonies that strengthen the taxpayer’s position.
• Align TP practices with economic substance to reflect the risks and activities of the entities involved.
• Stay updated on regulatory changes and case law developments.
• Conduct proactive risk assessments to address potential issues and identify optimisation opportunities.

How Forvis Mazars can help

Our Irish TP team has extensive experience across a wide range of industries, delivering tailored, sector-specific, and sustainable TP solutions that not only comply with increasingly stringent legislation but also align with your unique business needs.

We have the relevant experience in relation to TP planning, compliance, litigation and also in areas for preventing disputes from arising or resolving them through APAs/ MAPs. We work closely with the global Forvis Mazars network of TP specialists to deliver consistent, pragmatic and effective solutions and advice that transcend international borders.

If you have questions or would like to discuss related matters, please do not hesitate to contact us.