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Israeli Government Approves Proposal for Transfer Pricing Documentation Requirements Including CbC Reporting

13 August 2021

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Proposed Changes

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Israel

The Israeli Government has reportedly approved an updated proposal for amendments to the Income Tax Ordinance that provide for the introduction of the three-tiered transfer pricing documentation requirements developed as part of the BEPS project. This includes requirements for MNE groups to submit a Country-by-Country (CbC) report if group revenue exceeds EUR 750 million. The updated proposal would also require contemporaneous documentation to be submitted upon request from an assessing officer. Legislation for the new documentation requirements was first approved back in 2017, but never progressed beyond a first reading. Further information on the implementation of the requirements will be...