Israel's Transfer Pricing Amendment Proposals

The Israeli Ministry of Finance has published proposed significant amendments to the transfer pricing chapters of Israel's legislation for public consultation. Henriette Fuchs, Partner at Pearl Cohen Zedek Latzer Baratz looks at the detail of the proposed measures and analyzes what the changes mean for multinational enterprises operating in Israel.

Whilst Israel was among the early adopters of the Common Reporting Standard in 2018, the Third Phase Peer Review of the Organization for Economic Co-operation and Development (OECD) Inclusive Framework 2020, published on October 17, 2020, shows that at the end of 2019 Israel was still lagging behind with the implementation of rules for country-by-country (CbC) intergroup pricing reporting and the necessary legislative checks and balances for proper future international exchange of the CbC information eventually received. In August 2018, the OECD's mutual agreement procedure (MAP) minimum standard peer review had already