Dr. Brian Keegan:

There might be a situation where one company was renting a property belonging to another company, maybe at a discounted rate. If this is a strict arm's length transaction between two associated companies, would that be allowed? That is where it would come in. Generally, transfer pricing has to do with sales of products between companies. They are the trading transactions talked about. However, when talking about rental, as currently constituted, Irish transfer pricing would not look at those kind of structures.