The DEMPE Concept and Its Role in Domestic Transfer Pricing Practice – Report on Ireland

For chargeable periods beginning on or after 1 January 2020, in a transaction involving the transfer or use of intangibles, Irish taxpayers must be able to show DEMPE activities in order to justify returns to an intangibles-owner or to other parties to the transaction. Irish transfer pricing documentation rules require relevant taxpayers to prepare Master and/or Local Files in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and therefore require a taxpayer to engage with DEMPE in creating such documentation. If an Irish taxpayer desires to initiate a mutual agreement procedure or advance pricing agreement process involving the Irish Competent Authority, it should be prepared to show how DEMPE activities are occurring in the relevant transaction.This article is part of a special issue of the International Transfer Pricing Journal on the DEMPE concept in domestic transfer pricing practice. The other articles include the General Report and contributions on Belgium, France, Germany, Italy, Korea, Luxembourg, the Netherlands, Spain and the United States.