S.L. 123.207 Art. 1Citation and applicability. 

(1) The title of these rules is the Transfer Pricing

Rules.

(2) These rules shall apply for basis years commencing on or after 1st January 2024 in relation to any arrangement entered into on or after that date, and for those arrangements entered into before that date, these rules shall apply to those arrangements that are materially altered on or after the said date:

Provided that in relation to any arrangements entered into before 1st January 2024 and which were not materially altered on or after that date, these rules shall apply for basis years commencing on or after 1st January 2027.