Revenue eBrief No. 60/16 Guidelines on the operation of Ireland’s bilateral Advance Pricing Agreement (APA) programme.
Effective from 1 July 2016, Revenue is introducing a formal bilateral Advance Pricing Agreement programme.
In broad terms, a bilateral APA is a binding agreement between two tax administrations and the taxpayers concerned, which is entered into by reference to the relevant Double Taxation Agreement and which governs the treatment for tax purposes of future transactions between associated taxpayers.
Guidance on the operation of the programme is contained in Revenue’s Bilateral Advance Pricing Agreement Guidelines Tax and Duty Manual.
Source: Revenue Commissioners. www.revenue.ie. Copyright Acknowledged.