Ireland Transfer Pricing Documentation Requirements
Ireland sets two separate revenue thresholds for documentation: a Master File for groups above EUR 250 million and a Local File for groups above EUR 50 million. An exemption removes enterprises below the European SME threshold from the rules, and producing complete records within 30 days of a request is what preserves penalty protection.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Group consolidated revenue > EUR 250m | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN | Yes (fixed penalties; tax-geared penalties on adjustments) |
Local File Required | Group consolidated revenue > EUR 50m (SME exemption below the EU threshold) | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN | Yes (fixed up to EUR 25,000 plus EUR 100/day; tax-geared up to 100% of an adjustment) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Ireland deadline
Enter your entity’s fiscal year-end to return your exact Ireland preparation or filing date. Available without registration.
Scope of the documentation obligation
Ireland applies two distinct revenue thresholds. A Master File must be prepared by groups with consolidated revenue above EUR 250 million, while a Local File is required at the lower level of EUR 50 million of group revenue. Beneath these sits an exemption: where the group is below the European small and medium-sized enterprise threshold, broadly fewer than 50 employees and under EUR 10 million in turnover or assets, the Irish transfer pricing rules generally do not apply. The documentation is expected to exist by the tax return filing date and is produced within 30 days of a request from Revenue.
Distinctive features of the Irish regime
The distinctive feature of the Irish regime is the way penalty protection is conditioned. A taxpayer secures protection from penalties on a transfer pricing adjustment only where it prepares the appropriate records, provides them to Revenue within 30 days, and can demonstrate that the records are complete and accurate and that reasonable efforts to comply were made. Where that standard is not met, fixed penalties of up to EUR 25,000 plus EUR 100 for each day the failure continues can apply, and tax-geared penalties of up to 100 percent of the adjustment are available depending on the taxpayer’s conduct and the nature of any disclosure. The corporate tax return itself carries questions confirming whether the SME exemption applies and whether a Local File or Master File is required.
The status of the SME exemption is itself worth noting, as it has been flagged as a possible change to the regime and could be narrowed by ministerial order.
Benchmarking and comparables
There is no legal requirement to use local comparables, and pan-European comparable sets are accepted, with common practice extending to the EU member states, other Single Market participants, and the United Kingdom. Three-year testing is common practice for the benchmark, while the tested party is assessed on single-year results. For a profit-based analysis, Revenue generally expects a full benchmarking study every three years with the comparables’ financials refreshed annually. The limitation period is currently four years after the end of the accounting period in which the return is made.
Frequently asked questions
Do the Irish Master File and Local File share the same revenue threshold?
No. The Master File applies to groups above EUR 250 million of consolidated revenue, while the Local File applies from the lower level of EUR 50 million.
What does Ireland require for penalty protection on a transfer pricing adjustment?
The taxpayer must prepare appropriate records, provide them to Revenue within 30 days of a request, and be able to show they are complete and accurate and that reasonable efforts to comply were made.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.