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New Transfer Pricing Documentation Requirements for Israel

August 2, 2022

It used to be that a market study would suffice when it came to transfer pricing documentation in Israel. But not anymore. On June 30, the Israeli parliament approved BEPS Action 13’s three-tier documentation structure, essentially increasing compliance burdens for taxpayers meeting certain thresholds.

Know the new requirements:

The new requirements include a master file for taxpayers with group revenue exceeding 150 NIS million ($45 million), and while it’s supposed to be submitted within 60 days upon the tax authority’s request, that deadline is expected to reduce to 21 days.

A country-by-country report is also required for companies with annual revenue above NIS 3.4 billion (roughly $1.2 billion)—well over the OECD’s recommended 750 million euros, but the  Ministry of Finance may reduce that threshold as well.

Local companies may have to produce country-by-country reports if the ultimate parent entities in their groups don’t exchange with Israel. The legislation entered into force on July 5, but more regulations are needed to implement them—and they’re expected soon.