On 5 September 2018, the Israel Tax Authority (ITA) announced the publication of two circulars dealing with the issue of transfer pricing of transactions between related parties in international transactions. The first circular, Circular 11/2018, deals with the determination of the appropriate transfer pricing method for distribution, marketing, and sales activities of a multinational group in the domestic market. This includes that the attribution of arm's length remuneration should be determined after an analysis of functions, risks, and assets of the activity performed in Israel, with a distinction between full-fledged distribution activity in Israel, low-risk distribution activity, and marketing activity....