As previously reported, the Israeli Knesset (parliament) approved legislation on 30 June 2022 for the introduction of the three-tiered transfer pricing documentation requirements of BEPS Action 13. This includes: Country-by-Country (CbC) reporting requirement for MNE groups meeting a consolidated revenue threshold of ILS 3.4 billion; Stricter transfer pricing documentation requirements in line with the OECD Local file guidelines; and A Master file requirement for members of MNE groups with turnover exceeding ILS 150 million. The provisions of the law introducing the requirements, the Law to Amend the Income Tax Ordinance (Amendment No. 261) 2022, apply from the 2022 tax year,...