Many jurisdictions, including the United States and the United Kingdom incorporate such rules in their tax legislation. At present such rules exist in Ireland only to a limited extent and have little practical impact. Recently there has been public speculation that such rules might be included in the Irish tax code, although it is understood that the Revenue Commissioners have indicated that it is not on the agenda for the next 12 months. Superficially they seem reasonable and even attractive. It is well however before we do down that road to take heed of the monster which they have become in other jurisdictions.
Any large group is likely to do business across borders.
The classic example of a large cross border business is a US multinational. Inevitably a large part of the transactions of such a group are between group companies. US transfer pricing rules make it necessary for such multinational transactions out of the USA to be priced on an arm's length basis. The establishment of that basis is now a specialised discipline in itself. It requires the employment of teams of economists and tax advisers.