Transfer Pricing End-of-Year Adjustments in Ireland

End-of-year adjustments may be allowed by Irish Revenue once they are made prior to filing the company’s tax return. Once a return has been filed, procedures such as “self-correction without penalty” may be used to effect such adjustments provided that Revenue has not initiated a compliance intervention. APAs can provide some certainty for taxpayers in this area as the terms may include agreement with Revenue on year-end adjustment mechanisms.