Irish Revenue recently issued a report on the increasing importance of the role of the Irish competent authority in resolving international tax disputes, including the need to implement a formal program for entering into bilateral advance pricing agreements. Currently, the Irish tax authorities will generally be willing to enter into bilateral APAs on an ad-hoc basis where treaty partners are involved. In such cases, Ireland will follow the procedures of the jurisdiction of the foreign party to the APA. According to the report, Ireland needs to implement its own formal procedures in anticipation of the increased number of transfer pricing...