The EU General Court on 17 and 18 September 2019 held a hearing concerning a 2016 decision of the European Commission that two transfer pricing rulings granted by Ireland to a U.S. multinational group constituted illegal state aid.

Tax professionals have observed an increase in transfer pricing-related controversies and a related increase of advance pricing arrangement (APA) applications in various European countries.

The proposed changes to Ireland’s transfer pricing rules are expected to be introduced in Finance Bill 2019 and to come into force from 1 January 2020.

Overview of UK DST Digital services activity The UK DST is a 2% tax on revenues of businesses that provide