Transfer Pricing

The United Kingdom is currently promoting a new annual reporting obligation for international transactions between related parties. The change may be relevant to Israeli groups

What should be examined in loans between related parties, how an arm’s length interest rate is determined, and what can be learned from the recent

Transfer pricing is often associated with large multinational groups, public companies, and corporations with complex operations across dozens of countries. In practice, transfer pricing issues

How Intra-Group Transfer Pricing Adjustments May Create Indirect Tax Exposure Business groups operating in multiple jurisdictions are required to manage intra-group transactions in accordance with

Why the Same Price Between Related Companies Is Not Examined in the Same Way for Tax and Customs Purposes Importing goods from a related company

What the ITA is checking in your documents that you may be missing The adjustment has been made, the numbers have been aligned, the year

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:

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

When conducting a transfer pricing study, one must select the most appropriate comparison method to show that the prices set in a controlled transaction (i.e.,

When conducting a transfer pricing study, one must select the most appropriate comparison method to show that the prices set in a controlled transaction (i.e.,

When conducting a transfer pricing study, one must select the most appropriate comparison method to show that the prices set in a controlled transaction (i.e.,

Introduction to Advance Pricing Agreements – Transfer Pricing In the current business world, taxpayers seek assurance and confidence in handling their taxes and minimizing risks.

Maintaining the Arm’s Length Principle The arm’s length principle is rooted in a solid theoretical foundation as it closely mirrors the dynamics of the open

Introduction to Arm’s Length Principle The internationally recognized Arm’s Length Principle forms the basis of transfer pricing. It states that when related parties engage in

Methodology and Approaches of Transfer Pricing Studies Section 85A to the Income Tax ordinance, states that an international transaction between related parties (controlled transaction) should