Link Report

(a) such additional guidance, published by the OECD on or after the date of passing of the Finance Act 2022, as may be designated by the Minister for Finance for the purposes of this Part by order made under subsection (3), and

(d) the covered jurisdiction is a territory with the government of which arrangements having the force of law by virtue of section 826(1) have been made.

(i) in section 835C, the following subsection were substituted for subsection (4):

“OECD” has the same meaning as in section 835D(1);

“one-sided transfer pricing method” and “tested party” shall be construed in accordance with the transfer pricing guidelines (within the meaning of section 835D);

(ii) subject to paragraph (b), applying the transfer pricing method set out in the transfer pricing guidelines (within the meaning of section 835D) that is, in the circumstances, the most appropriate so as to determine the arm’s length amount of consideration for the identified arrangement.

(ii) in section 835D, the following definition were substituted for the definition of “transfer pricing guidelines”:

(b) For the purposes of paragraph (a)(ii), the transfer pricing method that is the most appropriate to determine the arm’s length amount of consideration for a qualifying arrangement (within the meaning of section 835DA) shall be determined in accordance with the OECD Pillar One Amount B guidance (within the meaning of section 835DA).’,

(b) For the purposes of paragraph (a)(ii), the transfer pricing method that is the most appropriate to determine the arm’s length amount of consideration for a qualifying arrangement (within the meaning of section 835DA) shall be determined in accordance with the OECD Pillar One Amount B guidance (within the meaning of section 835DA).’,

(b) the OECD Pillar One Amount B guidance (within the meaning of section 835DA);’,

(b) where the relevant person is a party to a qualifying arrangement to which section 835DA applies—

(i) the information specified in paragraph 60 of the OECD Pillar One Amount B guidance (within the meaning of section 835DA),

(iii) confirmation, in respect of each arrangement to which that section applies, and for each period referred to in subparagraph (ii), that the conditions referred to in paragraphs (b) and (c) of section 835DA(3) are satisfied,

(iv) confirmation that it is intended that the condition referred to in paragraph (c) of section 835DA(3) will be satisfied in respect of a qualifying arrangement for a minimum period of 3 years commencing from the first day of the first chargeable period to which section 835DA applies to the qualifying arrangement, unless—

(iv) confirmation that it is intended that the condition referred to in paragraph (c) of section 835DA(3) will be satisfied in respect of a qualifying arrangement for a minimum period of 3 years commencing from the first day of the first chargeable period to which section 835DA applies to the qualifying arrangement, unless—

‘(1A) A word or expression which is used in the definition in subsection (1) of “local file” and is also used in the OECD Pillar One Amount B guidance (within the meaning of section 835DA) has, unless the context otherwise requires, the same meaning in that definition as it has in the OECD Pillar One Amount B guidance (within the said meaning).’,

‘(3A) Where the relevant person is a party to a qualifying arrangement to which section 835DA applies for a chargeable period, the relevant person shall submit a notification to the Revenue Commissioners that the section applies, in such manner and form as may be prescribed by the Revenue Commissioners, no later than the date on which a return for the chargeable period is required to be delivered.’.

(b) as if in section 835G—