Taxes Consolidation Act 1997 section 835F

Small or medium-sized enterprise

Section 835F sets out the transfer pricing documentation rules for small and medium enterprises (SMEs), providing an exemption for small enterprises and simplified requirements for medium enterprises.

• Small enterprises (fewer than 50 employees, turnover/assets not exceeding €10 million) are fully exempt from the transfer pricing documentation requirements in section 835G.
• Medium enterprises (fewer than 250 employees, turnover not exceeding €50 million or assets not exceeding €43 million) must provide transfer pricing documentation only in respect of relevant arrangements.
• A relevant arrangement arises where the other party is not a qualifying person and annual consideration exceeds €1 million, or where an asset transfer involves a non-resident party and the asset's market value exceeds €25 million.
• Medium enterprises that are required to provide documentation must supply simplified information including a business description, copies of agreements, the transfer pricing method used, and a description of functions, risks, and assets.