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Ireland had no transfer pricing rules until 2010, which was well after the 1991 and 2007 tax rulings. http://www.pwc.com/gx/en/international-transfer-pricing/a

• spangry 10y ago
  That paper says that Ireland did have a limited transfer pricing regime (which they hadn't really enforced, or in PWC's words "Owing to these uncertainties, it is not believed that this section [1036] is applied in practice."). Also, from: http://europa.eu/rapid/press-release_IP-16-2923_en.htm http://europa.eu/rapid/press-release_IP-16-2923_en.htm ...the European Commission has concluded that two tax rulings issued by Ireland to Apple have substantially and artificially lowered the tax paid by Apple in Ireland since 1991. The rulings endorsed a way to establish the taxable profits for two Irish incorporated companies of the Apple group (Apple Sales International and Apple Operations Europe), which did not correspond to economic reality: almost all sales profits recorded by the two companies were internally attributed to a "head office". The Commission's assessment showed that these "head offices" existed only on paper and could not have generated such profits. These profits allocated to the "head offices" were not subject to tax in any country under specific provisions of the Irish tax law, which are no longer in force. As a result of the allocation method endorsed in the tax rulings, Apple only paid an effective corporate tax rate that declined from 1% in 2003 to 0.005% in 2014... Yep, that sounds like either transfer pricing or just direct income mis-attribution to me.