Revenue has issued eBrief No.41/10 which outlines the transfer pricing rules introduced by FA 2010 and the records required for the purposes of determining whether the trading income of the company has been computed in accordance with the requirements of section 835C.
The eBrief notes that the main purpose in having transfer pricing documentation available is to enable a company, if requested, to readily establish to Revenue’s satisfaction that its transfer prices are consistent with the arm's length requirements of section 835C.
Full details are available here