Ireland's transfer pricing legislation is based on the OECD arm's length standard which requires associated companies to price transactions on the same basis as independent parties would. Ireland’s legislation takes account of the OECD’s Transfer Pricing Guidelines. It is not correct to suggest that this legislation could be a basis for tax avoidance. The operation of the arm’s length standard and the OECD Guidelines as they apply in relation to intangible assets, including IP, are currently being considered by the OECD. Ireland is participating in this on-going OECD review of specific aspects of the international Guidelines and whether they may require adjustment in the context of the current organisation of global business.