The final report on the Base Erosion and Profit Shifting (“BEPS”) Project Action 14 – Making Dispute Resolution Mechanisms More Effective, which was part of the final package of BEPS measures, contains a best practice recommendation that countries should implement bilateral advance pricing arrangement (“APA”) programmes. In broad terms, a bilateral APA is is a binding agreement between tax administrations in two countries governing how future transactions between associated taxpayers established in their respective jurisdictions will be treated for tax purposes. An APA can cover a single transaction or a series of transactions.

Ireland’s new bilateral APA programme is effective from 1 July 2016 and applies to bilateral APA applications made to the Irish tax authorities on or after this date.

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