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Israel Approves Introduction of the Three-Tiered Transfer Pricing Documentation Requirements

21 July 2022

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Approved Changes

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Israel

On 30 June 2022, the Israeli Knesset (parliament) approved legislation for the long-delayed introduction of the three-tiered transfer pricing documentation requirements of BEPS Action 13. The legislation, which entered into force on 5 July 2022, amends the Income Tax Ordinance to provide that ultimate parent entities of MNE groups meeting a consolidated revenue threshold of ILS 3.4 billion are required to submit a Country-by-Country (CbC) report within 12 months following the end of the reporting fiscal year, with the possibility of a reduced threshold that may be established by the Ministry of Finance. Secondary local filing of CbC reports by...