6 min read
A transfer pricing dispute opened in Ireland in 2025 will not be resolved until 2028 at the earliest, based on published OECD averages. If it requires a mutual agreement procedure, the process may run considerably longer. Revenue's 2025 Annual Report, published on 7 May 2026, puts figures around what that environment now looks like in practice. The picture it presents is not simply one of greater enforcement. Revenue is operating through a more connected international framework in which transfer pricing disputes, treaty administration, information exchange and advance clearance mechanisms sit alongside one another rather than functioning independently. For businesses relying upon transfer pricing arrangements, treaty positions or wider cross-border structures, the report offers a clearer indication of what operating in that environment now requires.
During 2025, Revenue completed more than 237,000 audit and compliance interventions yielding approximately €734 million, alongside 189 tax avoidance interventions yielding €41.7 million. At the same time, 117 corporate groups accounting for approximately 65% of Ireland's net corporation tax receipts participated in Revenue's Co-operative Compliance Framework, a programme through which significant tax issues are raised and discussed on an ongoing basis rather than emerging later through dispute.
Viewed together, those figures describe an administration that is simultaneously more interventionist and more structured in how it engages with internationally active businesses. Revenue operates through an expanding treaty and information exchange network, with 75 double taxation agreements, 26 tax information exchange agreements and ongoing competent authority responsibilities across treaty disputes and arbitration mechanisms. The €13.4 billion collected through VAT One Stop Shop arrangements reflects the extent to which cross-border reporting and collection sit within an internationally coordinated system. Scrutiny and engagement are not at opposite ends of the spectrum. They operate alongside one another within the same cross-border framework.
The most significant figures in Revenue's 2025 Annual Report sit within the mutual agreement procedure statistics.
A mutual agreement procedure arises where two tax authorities seek to resolve competing tax outcomes affecting the same profits. Within a UK-Ireland context, that typically follows a transfer pricing adjustment where relief from double taxation depends upon HMRC and Irish Revenue reaching an agreed position through the treaty framework.
Revenue opened 2025 with 97 transfer pricing MAPs, received 41 new cases and concluded 22, producing a closing inventory of 116. New transfer pricing cases have increased from 29 in 2023 to 31 in 2024 and 41 in 2025. Resolutions have not kept pace. OECD statistics for 2024 placed Irish transfer pricing MAPs at an average of 35.57 months to conclude, above the OECD average of 30.9 months. A group entering a transfer pricing MAP with Ireland today is entering a process that runs for the better part of three years under current conditions, against a closing inventory that is growing rather than contracting.
The commercial consequence is direct. Where a cross-border disagreement extends across several years and involves more than one tax authority simultaneously, the quality of preparation assembled before the dispute begins determines how that process unfolds. Transfer pricing documentation, intercompany arrangements and the consistency of positions taken across jurisdictions carry materially greater weight once the same factual position is under examination from more than one direction at the same time.
An advance pricing agreement enables a business to agree the treatment of recurring cross-border transactions with one or more tax authorities in advance. Within UK-Ireland structures, that becomes relevant where financing arrangements, management charges, intellectual property or other intercompany relationships sit centrally within the group's operating model and where the commercial consequences of future disagreement would be material.
The APA figures from Revenue's Annual Report tell a clear story. Concluded agreements increased from one in 2023 to ten in 2024 and twelve in 2025, against an opening inventory of 80 cases and 13 new requests during the year. The programme is assuming greater practical relevance. The data equally shows that access to certainty requires commitment: two applications were rejected during 2025 and three withdrawn by taxpayers, while OECD statistics for 2024 placed Ireland's average APA completion period at 52.6 months, above the OECD average of 39.6 months.
Groups that want advance certainty need to plan for a process measured in years, not months, and need to arrive at it with a well-developed commercial rationale and carefully prepared transfer pricing analysis. Revenue's guidance confirms that participation remains discretionary. An early, well-supported application produces a materially different outcome from a preliminary enquiry submitted without adequate preparation behind it.
Revenue adapted its risk assessment processes during 2025 to make greater use of annual transfer pricing documentation. That single detail from the Annual Report carries more practical significance than the headline exchange volumes that surround it. Transfer pricing documentation is no longer functioning primarily as a compliance record. Revenue is using it as a tool for identifying risk across the group, which means the quality and consistency of that documentation now shapes how a business is assessed before any formal enquiry begins.
The exchange volumes themselves reflect how broadly that assessment can reach. During 2025, Revenue exchanged Country-by-Country reporting data with 71 jurisdictions, participated in Common Reporting Standard exchanges involving 119 tax administrations and continued sharing cross-border tax opinions through established frameworks. Revenue received 2,802 incoming requests for information from other jurisdictions and made 524 outbound requests. Ireland signed the GIR MCAA on 8 July 2025, committing to the central filing framework through which in-scope groups submit their initial transition year return by 30 June 2026, ahead of the 31 December 2026 commencement of automatic competent authority data exchanges.
The practical consequence is that differences between transfer pricing outcomes, treaty positions, withholding tax treatment and wider reporting are progressively easier for tax authorities to identify where more than one jurisdiction is examining the same structure simultaneously. Information prepared for one purpose is available for another.
The data in Revenue's 2025 Annual Report makes the cost of inadequate preparation quantifiable in a way it has not always been.
A group that enters a transfer pricing MAP without well-developed documentation and consistent cross-jurisdictional positions faces a process lasting the better part of three years, against a growing caseload and an information environment in which Revenue and HMRC each hold more data about the group than most businesses have formally assembled for themselves. A group that applies for an APA without adequate commercial rationale and transfer pricing analysis risks rejection or withdrawal after a process already running into years.
The route to certainty remains available. The APA programme is concluding more cases. The Co-operative Compliance Framework demonstrates that Revenue engages substantively with groups that come prepared. What the Annual Report makes clear is that the standard required to operate confidently within this environment has risen, and that the consequences of not meeting it arrive earlier and run longer than many groups currently anticipate.