The Israeli Tax Authority (ITA) has issued Circular 1/2020 of 2 June 2020 concerning the burden of proof and documentation requirements in transfer pricing audits. Under Section 85A of the Israeli Income Tax Ordinance (ITO), taxpayers are required to submit transfer pricing documentation and supporting information within 60 days of request by the ITA. This is typically submitted as a transfer pricing study, which should be prepared in accordance with the related regulations. Where the transfer pricing study is submitted, Section 85A provides that the burden of proof is shifted to the assessing officer in the event the officer determines...