Transfer Pricing

What Has Changed for US Groups – and What Still Requires Preparation In 2026, the Pillar Two rules are no longer only a matter for

What Interests the Tax Authority, and How Can Exposure Be Reduced? When a company operates only in Israel, it is usually quite clear where the

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: