Dear Clients, Colleagues, and Friends,

On June 2, 2020, the Israel Tax Authority (“ITA”) issued a tax circular (Tax Circular 1/2020) which had been under review and debate for some months now, regarding the burden of proof in transfer pricing audits (and documentation). Tax Circular 1/2020 reiterates the views of the ITA on when (an indeed if) the burden of proof in transfer pricing audits shifts from the taxpayer to the ITA.

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Herzog Fox & Neeman is the only law firm in Israel with a transfer pricing department which provides complete transfer pricing services, including the required transfer pricing studies.
We encourage you to contact us in order to verify that your transfer pricing methodology and studies are in compliance with the local requirements.

Best Regards,
Tax Department
Herzog Fox & Neeman