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Israel’s Tax Authority releases tax circular on burden of proof related to transfer pricing audits

05 June 2020

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Tax Alerts, National/Federal Taxation, T...

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Israel

Executive summaryThe Israeli Tax Authority (ITA) published, on 2 June 2020, a tax circular that sets forth the situations in which a transfer pricing (TP) study that is filed by a taxpayer will be considered as meeting the Israeli TP standards in accordance with Section 85A of the Income Tax Ordinance (ITO) and its Regulations (the Circular). If the TP study is considered to meet the requisite standards, the burden of proof, as part of the audit procedure, will transfer from the taxpayer to the tax assessor to rebut the facts and analysis performed by the taxpayer. Accordingly, the appropriate documentation...