Transfer Pricing - guidelines for implementing the CBCr
14 February 2023
Further to our last publication regarding the approval of the new transfer pricing legislation[1][2], additional guidelines for reporting the CBCr are now being published by the Israeli Tax Authorities (ITA).
The CBCr (Country by Country report) is an international report that includes comprehensive and detailed information regarding all entities of the multinational group. The preparation of the report applies to a multinational group whose turnover in the year preceding the reporting year exceeds 3.4 billion NIS. The report will be forwarded as part of an automatic exchange of information to other countries.
Here are the main points:
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Notifying the ITA of its intentions regarding the reportin |
Submitting a CBCr in Israel |
| An ultimate parent entity resident of Israel, which is obligated to report in Israel |
Form 1585 must be attached to the annual tax return |
Within 12 months from the end of the tax year (for the year 2022it must be submitted by the end of 2023).
Submission method - online report through a specific system |
| An ultimate parent entity resident of Israel, which is obligated to report in Israel, but wishes to submit a CBCr in a foreign country and not in Israel |
Report by the end of the tax year (For tax year 2022 until the end of 2022)
In addition, Form 1585 must be attached to the annual tax return |
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A local entity related to a foreign group, where the ultimate parent entity in the foreign group submits a CBCr outside of Israel
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Form 1585 must be attached to the annual tax return, in addition to a specific email to the ITA |
There is no obligation to submit in Israel (certain exceptions according to guidelines that will be published in the following months). |
For further details and assistance, please contact:
C.P.A. (Adv) Amit Shalit, Partner and Head of Transfer Pricing
By email: AmitS@bdo.co.il or by telephone: 052-6008056
[1]Approval of a bill in the field of transfer pricing- effective from 2022 - BDO
[2]Update for documentation requirement - Transfer pricing regulations - In effect from 2022 - BDO
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