A&L Goodbody has a focus on M&A transactions involving Ireland, which is where the majority of its transfer pricing work is focused. As well as advising on the transfer pricing issues of cross-border transactions, the firm is also active in transfer pricing disputes with the authorities.
The transfer pricing department of Deloitte Ireland has continued its assistance to high growth and MNEs over the past year, focusing on providing advice on the developing BEPS initiatives being published by the OECD, as well as advising on the changing transfer pricing regulations within Ireland. In addition to providing analysis and advisory services, it also offers a number of digital systems designed to assist clients with the collection, documentation and reporting of transfer pricing policies. Its transfer pricing department is headed by Gerard Feeney, who has led the team for the past four years.
Deloitte Ireland recently assisted a high-growth clothing business in the optimisation of its transfer pricing business model. This involved designing and implementing a business model in line with the current BEPS regulation, while mitigating the risk of challenges on permanent establishment and limiting risk distributors in foreign jurisdictions.
The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.
Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.
Mason Hayes & Curran, a leading Irish law firm, has grown its transfer pricing offering in Ireland, focusing on giving advice to American MNE's on Irish domestic policy with regard to transfer pricing agreements for Ireland-based companies. The tax department is led by John Gulliver, who also advises on transfer pricing matters.
The firm recently assisted a major US insurance broker on the effects to current cost-sharing agreements of a proposed development and expansion of its Irish IP R&D centre.
Matheson is a leading Irish law firm for transfer pricing. John Ryan is the chair of tax, with partners Catherine O'Meara, Brian Doohan and Joe Duffy assisting clients with transfer pricing matters. The firm advises on the negotiation of APAs, commonly between the US and Ireland, as well as supporting clients undergoing tax audits and pre-audit transfer pricing queries from the Irish revenue. Following a 2016 ruling, the partners along with the firm’s EU and litigation team, advise a number of clients on state aid matters.
William Fry's transfer pricing department includes former Deloitte professionals Shane Wallace and Declan Lavelle, as well as head of William Fry tax advisors and member of the Taxand board, Martin Phelan. The firm regularly assists in discussions on MAPs and APAs for their clients, as well as discussions with authorities and advice on business organisation.