When multinationals come to Ireland to locate international business centres and declare billions of euro in taxable profits here, they engage in transfer pricing. This specialist branch of accounting deals with the amounts international subsidiaries of the same group charge each other when they trade across borders to buy and sell goods and services, transfer assets or borrow from one another. Over the past decade, coordinated government efforts under the OECD’s Base Erosion and Profit Shifting (BEPS) project have attempted to police transfer pricing, strengthening rules such as the arm’s length principle under which sister companies should charge each other…

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