On 23 June 2016, Irish Revenue issued guidelines on the operation of the new bilateral advance pricing agreement (APA) program, which is effective from 1 July 2016. In the past, the Irish Revenue Commissioners have generally been willing to enter into APAs on an ad-hoc basis where treaty partners are involved, but had no formal program. The main aspects of the new program are as follows:
- All taxpayers are allowed to apply for an APA in respect of transactions between separate business enterp…