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  • Article

    Tax Alert: Cost-Plus Taxpayers? Amend Your Tax Return, Or Else…

    The announcement includes an explicit warning that the relevant taxpayers who will not amend their previous years' tax returns are exposed not only to higher income tax adjustments, but also in certain cases, to penalties.
    IsraelTax
    Pearl Cohen Zedek Latzer Baratz
    Pearl Cohen Zedek Latzer Baratz
  • Article

    Implications Of The New Updated Form 1385 - Declaration Of International Transactions Between Related Parties

    early July, the Israeli Tax Authority (ITA) issued an update to Form 1385 - "Declaration of International Transaction."
    IsraelTax
    Pearl Cohen Zedek Latzer Baratz
    Pearl Cohen Zedek Latzer Baratz
  • Article

    New Court Decision On Transfer Pricing Taxation

    Earlier this month the Central District Court handed down its decision on an appeal involving the taxation of an international sale of intellectual property by Gteko Ltd., an Israeli subsidiary of Microsoft Corporation.
    IsraelTax
    Barnea & Co
    Barnea & Co
  • Article

    A Precedential Judgment In The Matter Of Transfer Pricing Shuffles The Cards As To Granting Options To Employees

    A judgment in the Kontera case was handed down two weeks ago in the District Court which dramatically changes the Cost Plus issues relevant to certain Israeli companies...
    IsraelTax
    Barnea & Co
    Barnea & Co
  • Article

    Israeli District Court: In An IP/FAR Tax Case The Burden Of Proof Is On The Taxpayer

    The Tel Aviv District Court recently delivered a decision in a tax appeal of Broadcom, finding that the burden of proof is on the taxpayer regarding whether a transaction has to be treated as an intellectual property...
    IsraelTax
    Herzog Fox & Neeman
    Herzog Fox & Neeman
  • Article

    The Israeli Tax Authority Issued New Circulars On Transfer Pricing

    When a transaction is made between unrelated parties, the difference in interests results in the price and the conditions of the transaction reflecting the market conditions.
    IsraelTax
    Gross, Kleinhendler, Hodak, Halevy, Greenberg & Co.
    Gross, Kleinhendler, Hodak, Halevy, Greenberg & Co.
  • Article

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

    The current wording of section 1 of the ITO provides that a body of persons would be deemed an Israeli resident if it was either incorporated in Israel or if its business is managed and controlled in Israel.
    IsraelTax
    S Horowitz & Co
    S Horowitz & Co
  • Article

    Increased Transfer Pricing Scrutiny Israel ~ Cross Border Financing

    In the third week of October, the District Court in Jerusalem released its decision in connection with the – very tax relevant – difference between a "loan" and a "capital note"...
    IsraelTax
    Pearl Cohen Zedek Latzer Baratz
    Pearl Cohen Zedek Latzer Baratz
  • Article

    Israel Tax Highlights - 2016

    Israeli tax law is changing regularly. There were various amendments to the Israeli Tax Code, including the reduction of tax rates. The following summarizes Israeli tax rates and other tax information for 2016.
    IsraelTax
    Dr. Avi Nov Law Office
    Dr. Avi Nov Law Office
  • Article

    Change Of A Business Model In Multinational Groups

    The Circular states that it follows the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations from 2017.
    IsraelTax
    Herzog Fox & Neeman
    Herzog Fox & Neeman
  • Article

    Israeli Hi-Tech Founders Debating: "To Be Or Not To Be An Israeli Company"

    Many entrepreneurs need to make a decision where to incorporate their company.
    IsraelTax
    Gross, Kleinhendler, Hodak, Halevy, Greenberg & Co.
    Gross, Kleinhendler, Hodak, Halevy, Greenberg & Co.
  • Article

    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.
    IsraelTax
    Pearl Cohen Zedek Latzer Baratz
    Pearl Cohen Zedek Latzer Baratz

Showing 1–12 of 12 results