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How to survive a transfer pricing audit in Israel

March 14, 2008

Eran Shif, of Ernst & Young in Israel, describes the approach of the Israeli tax authorities to transfer pricing audits

Although the Israeli Transfer Pricing Regulations (ITPR) were issued on November 2006, transfer pricing audits began already several years earlier, albeit to a limited extent. Two events in the last year have significantly increased the exposure of transfer pricing in tax audits. The first was the issuance of the ITPR in the end of 2006, which provided the legal frame of arm’s length and the right to request documentation related to transfer pricing. The second was the publication of form 1385 in the last quarter of 2007. In this form, that has to be submitted along with the annual tax return, a taxpayer must:

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