At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: Office of the Revenue Commissioners (Revenue). Summaries are simplified; check the linked official source before relying on them.
The law
#Transfer pricing is in Part 35A of the Taxes Consolidation Act 1997 (TCA 1997 ss. 835A-835HB), substituted by Finance Act 2019 s. 27 for chargeable periods from 1 January 2020. s. 835C is the arm's length rule and s. 835D requires the rules to be read consistently with the OECD Transfer Pricing Guidelines (the 2022 version for periods from 1 January 2023, per Finance Act 2022).
Documentation
#s. 835G: groups with consolidated global revenue of EUR 250m or more must prepare a Master File, and groups with EUR 50m or more a Local File, both in OECD Annex I / Annex II format. Files must be prepared no later than the CT1 filing date for the period (s. 835G(5)(a)) and provided within 30 days of a written Revenue request (s. 835G(5)(b)). Files are not filed with the return. Below the thresholds, taxpayers must still keep records showing arm's length pricing.
Methods
#OECD Guidelines methods apply through s. 835D, with the most appropriate method for the case. No local method hierarchy.
Penalties
#Failing to provide TP documentation within 30 days of a request: fixed penalty of EUR 25,000 plus EUR 100 per day (EUR 4,000 for taxpayers below the Master File and Local File thresholds). Penalty protection under s. 835G(7): if documentation was prepared on time, provided within 30 days, and is accurate and shows reasonable efforts, no tax-geared penalty applies to a TP adjustment in the careless (not deliberate) category under ss. 1077E / 1077F.
Pillar Two
#Ireland's Part 4A TCA 1997 applies the IIR and QDTT from fiscal years starting on or after 31 December 2023 and the UTPR from 31 December 2024. Entities register once within 12 months of the first in-scope year end (extended to 28 February 2026 for 2024). The GIR (or notification of filer) and the QDTT, IIR and UTPR returns and payments are all due 15 months after year end, 18 months for the first year, never before 30 June 2026.
Other rules
#Small and medium enterprises (EU definition) remain excluded under s. 835EA; s. 835F, which would bring them in, needs a ministerial commencement order not yet made. s. 835E excludes certain Irish-to-Irish non-trading transactions. Revenue runs a bilateral APA programme. Interest limitation rule (TCA 1997 Part 35D, s. 835AY onward) limits exceeding borrowing costs to 30% of tax-EBITDA, with a EUR 3m de minimis for a 12-month period. No formal secondary adjustment rule. CT1 late filing surcharge is 5% (max EUR 12,695) or 10% (max EUR 63,485).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC notification Notify Revenue (via ROS) of which entity will file the CbC report, no later than the last day of the fiscal year the report covers. | Last day of the fiscal year (e.g. Dec 31, 2025) | Irish constituent entities of MNE groups with consolidated revenue of EUR 750m or more in the prior fiscal year. | Revenue Tax and Duty Manual Part 38-03-21 (Country-by-Country Reporting) |
| 2 | Corporation tax return (Form CT1) Due by the 23rd day of the 9th month after period end when filed and paid through ROS (21st if not via ROS). If the period ends before the 21st of a month, the deadline is the same day 9 months later instead (for example 5 December year end files by 5 September). The 9-month rule and the day 21 / day 23 cap come from the definition of specified return date in TCA 1997 s. 959A. | Day 23 of the 9th month after year end (e.g. Sep 23, 2026) | All companies within the charge to Irish corporation tax. | Revenue: Corporation Tax payment and filing |
| 3 | Master File prepared (s. 835G) Must exist by the CT1 filing date. Kept, not filed. | With Corporation tax return (Form CT1) (e.g. Sep 23, 2026) | Entities in an MNE group with total consolidated global revenue of EUR 250m or more in the chargeable period. | Revenue Tax and Duty Manual Part 35A-01-01 |
| 4 | Local File prepared (s. 835G) Must exist by the CT1 filing date. Kept, not filed. | With Corporation tax return (Form CT1) (e.g. Sep 23, 2026) | Entities in an MNE group with total consolidated global revenue of EUR 50m or more in the chargeable period. | Revenue Tax and Duty Manual Part 35A-01-01 |
| 5 | Country-by-Country report Due 12 months after the last day of the fiscal year (TCA 1997 s. 891H and the CbC Regulations). | 12 months after year end (e.g. Dec 31, 2026) | Irish ultimate parent of an MNE group with consolidated revenue of EUR 750m or more in the prior fiscal year, or an Irish entity required to file locally. | S.I. No. 653/2016 Taxes (Country By Country Reporting) Regulations 2016 |
| 6 | Top-up Tax Information Return (GIR) or notification of filer Due on the specified return date: 15 months after year end, 18 months for the transition year, and never before 30 June 2026. If the GIR is filed abroad, a notification of filer is due by the same date. Late penalty is EUR 10,000 per month, up to 48 months, with transitional relief for years starting on or before 31 December 2026 where reasonable care was taken. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | Revenue Tax and Duty Manual Part 04A-01-01 |
| 7 | Top-up tax returns (QDTT, IIR, UTPR) and payment Separate QDTT, IIR and UTPR returns, nil returns included, due on the specified return date, with tax payable the same day. Late return surcharge: 5% (max EUR 50,000) if up to 2 months late, 10% (max EUR 200,000) after that. IIR and QDTT apply from fiscal years starting on or after 31 December 2023; the UTPR from 31 December 2024. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | Revenue Tax and Duty Manual Part 04A-01-01 |
| 8 | Master File and Local File provided on request 30 days from a written request by a Revenue officer (s. 835G(5)(b)). Late: EUR 25,000 plus EUR 100 per day for groups above the thresholds; EUR 4,000 for smaller taxpayers. | Within 30 days of a tax authority request | Groups at or above EUR 50m (Local File) or EUR 250m (Master File). Smaller taxpayers must also provide their records within 30 days. | Revenue Tax and Duty Manual Part 35A-01-05 |
| 9 | Pillar Two registration (one-time) Each entity subject to the IIR, UTPR or QDTT registers with Revenue within 12 months of the end of its first in-scope fiscal year. For calendar 2024 the date was moved to 31 December 2025 and then extended to 28 February 2026. Penalty EUR 10,000. Changes must be notified within 12 months of the year end. | One-time: due only for the first year in scope | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | Revenue Tax and Duty Manual Part 04A-01-01 |
Official texts
#- TCA 1997 Part 35A (transfer pricing), revised (Not confirmed (Law Reform Commission revised Acts))
- Finance Act 2019 (substituted Part 35A), as enacted (Oireachtas (Open Data) PSI Licence (applies CC BY 4.0))
- S.I. No. 653/2016 CbC Regulations (Oireachtas (Open Data) PSI Licence (applies CC BY 4.0))
- Revenue Tax and Duty Manuals Part 35A (TP guidance) (Not confirmed (Revenue copyright))