When it comes to determining a solid inter-group international transfer pricing, some tax professionals take the approach of "ignore and it will go away". It will not. Every year, more countries follow the U.S. lead whereby companies are challenged on their inter-group transfer pricing strategies and imposing onerous penalties often leading to double taxation. Waiting is not an advisable and even risky approach. Deloitte world wide has a special reputation in the field of transfer pricing, its specialists and tools are considered authoritative leaders in the field.
Israel law have followed the US transfer pricing rules like many other countries, and determined in its internal tax law, special rules with regards to transfer pricing. According to the provisions determined under the Israeli tax law, if in an international transaction, there are special relationships between the parties, because of which the price or other conditions of the transaction were set so that a smaller profit was realized, then the transaction shall be reported in accordance with the market conditions and charged tax accordingly.
For more information please contact:
Head of Transfer Pricing services
Tel: +972 (3) 608 5424