Irish Tax Appeal Commission rules on treatment of stock-based compensation in services cost base transfer pricing dispute

In a recent determination overturning an assessment by the Irish Revenue Commissioners (59TACD2024 — Corporation Tax (taxappeals.ie)), Ireland's Tax Appeals Commission (Commission) ruled that the cost of stock-based awards (SBAs) should be borne by the US parent company, not its Irish subsidiary; as such, the Irish subsidiary did not need to include the SBAs in its cost base for the transfer prici…
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