Transfer Pricing

Transfer Pricing ("TP") is a relatively new and challanging area within the field of international taxation. Due to its focus on inter-company transactions which are growing rapidly and are becoming much more complex, TP aspects affect nearly all areas of multinational group operations; inlucding, inter alia, manufacturing, marketing, distribution, research & development activities.

We have acquired extensive knowledge in the International TP field and can assist you with your TP issues in the aforementioned ways. As time passes, regulations tighten and penalties increase, now is the time to get your TP in order to face one of the most pressing international tax issues of recent times.

The Transfer Pricing Team is comprised of accountants, lawyers, and economists experienced both in Israel and abroad. The team offers transfer pricing services catered to both the local and international tax strategy of the client.  The TP department is headed by Amit Shalit (CPA, Adv.) which specializes in international tax combined with transfer pricing, providing an added-value for our clients.

Services:

• TP Policy: Assisting you in determining the appropriate TP policy which your organization can adopt.
• Documentation: Assisting you on maintaining the documentation requirements of the Israeli Tax Authorities ("ITA") and any other relevant authorities for TP matters, e.g., preparation of a transfer pricing reports, etc.
• ITA Audits: We can assist you with any Tax Audits performed by the ITA on your organization. This can include assistance on formulating an audit defense and / or dispute resolutions, performing advance checks of an ITA audit in order to highlight exposures or risks and to provide you with a clean bill of health and "peace of mind" in advance of signing the relevant tax return.
• APA Services: We can assist you in obtaining an Advanced Pricing Agreement ("APA") , i.e., a tax ruling whereby one or more tax authorities contractually agree not to challenge your transfer pricing policies for a number of years.
• Global BDO TP Team: We are part of the global BDO TP Network and have access to our colleagues for assistance in connection with TP issues in other countries, if necessary.
• Additional tailored TP relevant issues that may be relevant.