At the same time, Revenue scrutiny in this area has intensified, with a clear willingness to challenge multinational groups where intercompany arrangements are not considered to reflect the arm’s length principle.
On 7 May 2026, Revenue published its Annual Report 2025 together with various research and statistical papers. A review of Ireland’s Revenue Annual Reports 2025 (and 2024) provides insight into how transfer pricing enforcement is evolving in practice. While the policy direction remains broadly consistent, the underlying data suggests it is becoming more targeted, more data-led and increasingly integrated with broader international tax developments.
From a purely numerical perspective, the trajectory is clear. By the end of 2024, 46 transfer pricing interventions had been finalised since 2015, generating €788 million in yield. By 2025, this had increased to 55 interventions and €824 million in yield, alongside continued restrictions on trading losses exceeding €1 billion.
This is not simply a story of increased activity. Rather, it reflects the continued progression of complex cases through the audit cycle, with an observable impact on cash collections and tax base adjustments.
More broadly, a number of themes emerge from the 2025 report that will be particularly relevant for multinational groups.
The first is the continued positioning of transfer pricing as a core compliance priority. Revenue explicitly reiterates that risk-driven transfer pricing audits remain a key focus area, with a commitment to proactively identify and confront non-compliance. While this aligns with prior years, the execution appears to be evolving. In particular, the 2025 report highlights a more systematic use of annual transfer pricing documentation in the risk assessment process.
From a consultative perspective, this is a noteworthy development. It suggests that documentation is increasingly being used not only to support positions under audit, but also to determine which cases are selected for review in the first instance.
For groups operating in Ireland, this reinforces the importance of ensuring that transfer pricing documentation is internally consistent and aligned with financial and operational data. Any disconnect between the narrative in the documentation and the underlying numbers is more likely to be identified at an earlier stage.
Second, dispute resolution activity continues to point to the complexity of cross-border profit allocation. In 2024, 24 of the MAP cases resolved related to transfer pricing, while in 2025, 22 transfer pricing MAP cases were concluded. This sustained level of activity underlines that transfer pricing remains one of the primary drivers of double taxation disputes.
At the same time, there is a gradual increase in the use of advance certainty mechanisms. Advance Pricing Agreements concluded rose from 10 in 2024 to 12 in 2025. In our experience, this reflects a growing preference among multinational groups to proactively manage transfer pricing risk, particularly in an environment where margin outcomes are under greater scrutiny.
Third, the interaction between transfer pricing and the wider international tax framework is becoming more pronounced. The 2025 report places significant emphasis on Pillar Two readiness, including the development of systems for registration, filing and information exchange, as well as enhanced communication with in-scope groups. In parallel, there is continued engagement at EU level on a proposed transfer pricing directive and related measures.
Taken together, this points towards a more integrated compliance environment. Transfer pricing outcomes will increasingly need to be considered alongside Pillar Two calculations, Country-by-Country reporting data and information exchanged with other tax authorities.
The 2025 Annual Report underlines the growing role of data and analytics in shaping Revenue’s approach. The use of Country-by-Country reporting data to support high-level transfer pricing risk assessment is specifically highlighted, alongside broader data matching and international exchange mechanisms.
From a practical standpoint, this reinforces a key message for businesses. Transfer pricing is no longer assessed in isolation. It is being evaluated in the context of multiple data sources, both domestic and international, with increasing sophistication.
In our view, the overall direction is clear. The Irish transfer pricing landscape is not undergoing a fundamental shift in policy, but rather a steady refinement in how existing rules are applied. For multinational groups, this means that the focus should extend beyond technical correctness. Greater emphasis is being placed on consistency across documentation, alignment with financial data and coherence with the wider tax profile of the group.
As these trends continue, early engagement, robust documentation and, where appropriate, proactive dispute prevention mechanisms will remain central to managing transfer pricing risk effectively.
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