New Aggressive Bill - Management & Control Presumption And Transfer Pricing Liabilities

It was only recently that we published an article reviewing the recently enacted tax provisions concerning corporate taxation and capital investments encouragements, which were enacted as part of approving the economic policy program and the government budget for the years 2017 and 2018. Surprisingly, this week, the Israeli government published a new bill ("the Bill"), proposing additional amendments of the Israeli Tax Ordinance (New Version), 1961 ("the ITO"). The Bill proposes revolutionary provisions concerning management and control of companies registered outside Israel ("Management & Control") amendments to the provisions concerning Controlled Foreign Company ("CFC"), and new liabilities concerning Transfer Pricing ("TP").