Bilateral Advance Pricing Agreement Guidelines
Revenue has introduced a formal Bilateral Advance Pricing Agreement (APA) Programme which becomes effective from 1 July 2016. A bilateral APA is a binding agreement that allows the taxpayer and two tax authorities to avoid future transfer pricing disputes by entering into a prospective agreement regarding the taxpayer’s transfer prices.
Guidelines on the operation of the programme are contained in Revenue’s Bilateral Advance Pricing Agreement Guidelines and further details are contained in Revenue eBrief No. 60/16 on here.