Revenue has stated that it will not extend the period for which a Bilateral Advance Pricing Agreement (APA) will be granted beyond 5 years from the date of the agreement with the tax authority.

As already reported, the Bilateral APA programme was introduced from 1 July 2016 and allows a taxpayer and two tax authorities to enter into a binding agreement regarding the taxpayer’s transfer prices. The guidelines on the operation of the programme are contained in Revenue’s Bilateral Advance Pricing Agreement Guidelines and have been updated for this confirmation and eBrief 81/2016 on here contains more details.