Documentation and reporting are fundamental pillars of transfer pricing compliance. Without proper documentation, a company may struggle to demonstrate adherence to the arm’s length principle.
Insights from the Kontera Technologies Ltd. Ruling Transfer Pricing and proper intercompany Pricing are a complex challenge for international companies. One of the key questions
The cost plus method When conducting a transfer pricing study, it’s essential to select the most appropriate comparison method to demonstrate that the prices set
Amendment 261 to the Israeli Tax Ordinance (The Ordinance), which was published to the Knesset Records in July 2022, updates the reporting obligations of an
Overview of Coca-Cola Ruling: Central Company vs. Gush Dan Tax Officer The Tel Aviv District Court recently mandated that the central company for soft drink
In February 2025, the Israeli Tax Authority published Circular 01/2025 on transfer pricing – Amendment 261 to the Income Tax Ordinance – Country-by-Country Report (hereinafter:
The transfer pricing branch belongs to the field of international taxation and deals with situations where there are international transactions between related parties. In the
When carrying out a transfer pricing study, it’s essential to choose the most suitable method for demonstrating that the prices in a controlled transaction (that
