The role of the Transfer Pricing team is to assist clients with ensuring that their transactions between related parties are priced on comparable terms to similar transactions that would have been performed had the parties not been related. To put it simply, between third-parties or to ensure transactions are conducted at arm’s length.
Common inter-company transactions include the provision of tangible goods, services, intellectual property and financing. Tax authorities around the world have an interest in ensuring that inter-company transactions are priced on arm’s length terms to avoid companies using transfer pricing to put disproportionate amounts of profit in low tax jurisdictions. As such there is a general body of transfer pricing guidance issued by the OECD. While the Transfer Pricing team operates in the wider tax function, the majority of our work relies on economic principles and considering what commercial enterprises might do if the transaction we are looking at was between two unrelated parties. Transfer pricing sits within the overall tax practice and specifically within the International Tax Services sub-service line.
As Irish transfer pricing rules primarily apply to only the largest companies, the majority of our clients are the larger Irish Groups or foreign multinationals with a presence in Ireland. Our work spans across all industries, however with technology and pharmaceutical being two of the biggest sectors in Ireland, our work in these areas is more common. We work on a variety of types of transactions, be it acquisitions, restructurings, or just the day-to-day operations of a business.
In our team we have a range of academic backgrounds, from economics, to law, to business and mathematics. While transfer pricing is primarily focused on economics, an economics degree is by no means a pre-requisite. We’re looking for people with a natural curiosity and inquisitive nature, and a general interest in business issues. People who can look at a situation and can rationalise how it happened, or hypothesise what might happen next.