Tax
Transfer Pricing
Our transfer pricing team offers Israel’s most comprehensive guidance on international transfer pricing, helping our clients to avoid costly audit, disputes and penalties. The team’s outstanding command of both Israeli and global requirements has resulted in an unmatched acceptance rate of their transfer pricing reports by both Israeli and worldwide tax authorities. Herzog Fox & Neeman is the only law firm in Israel that provides full transfer pricing services; the fact that under Israeli law our clients' matters are privileged and confidential, serves as an additional advantage of planning your international structure together with us.
Matching the continuously growing globalisation of Israeli companies and the increasing amount of foreign companies setting activities in Israel, our transfer pricing practice provides coherent transfer pricing solutions, responsive to the rapidly-changing markets in which multinational enterprises ("MNE") operate. Our transfer pricing team is experienced in complex and sophisticated matters of international tax and transfer pricing, and assists our clients in establishing their operations in Israel and abroad, as well as in documenting and protecting their intercompany transactions. When needed, our team also represents our clients in front of the tax authorities and in court.
Our practice is experienced with APAs and MAPs, and provides the full range of services to its clients, focusing on the legal, economic, and business related aspects of the client's tax structure and supply chain, employing innovative solutions. We represent our clients in both inbound and outbound transactions, in restructuring, audits, and of course the preparation of the required documentation in accordance with the changing regulatory environment, including the implementation of FAR, DEMPE and Value Chain Analysis. Each Master File, Local File, intercompany agreement and transfer pricing study we conduct, is given the full attention of the practice leader, attorney and economist Eyal Bar-Zvi.
Eyal often participates in discussions with and consults the Israeli Tax Authorities on transfer pricing circulars and the adequate interpretation and implementation of the OECD and other international transfer pricing regulations, shaping the future of transfer pricing regulations in Israel. Eyal serves as an adjunct professor and frequently lectures to the Israeli CPA Association on transfer pricing related matters.
Our services include:
- Transfer pricing planning
- Master File, Local File, and transfer pricing studies
- Intercompany agreements
- Transfer pricing policies (SOP)
- Advance pricing agreements (APA)
- Mutual agreement procedures (MAP)
- Transfer pricing implementation
- Intercompany finance
- DEMPE and profit split analyses
- Transfer pricing M&A Due Diligence
Transfer Pricing News & Insights
Eyal Bar-Zvi, LLB, LLM, BA (Eco), partner and head of the transfer pricing department, Herzog Yossi Shebson, BA (Eco), transfer
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Israeli Coca-Cola Ruling Expands the Arm’s Length Principle
Electronic Stock has recently acquired CRTEAM as part of its strategic expansion into the supply of electronic parts and circuits,
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Electronic Stock Acquires CRTEAM to Broaden Global Supply Operations
Our team is looking forward to 2024, and we are confident that our new partners, the majority of whom are
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We are happy to introduce our new partners
We are delighted to announce that in this year’s BDICode ranking, we are ranked in the top-tier in no less
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Herzog is ranked by BDi Code as the top tier in 38 practice areas for 2023
During the importation and assembly in Israel of their 737 and 787 simulators, Herzog assisted Avenger Flight Group, LLC with complex commercial,
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The world’s largest flight simulator company is arriving to Israel
As with most OECD countries, Israeli companies and/or PEs are required to meet the local transfer pricing requirements, which include
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Updates to Transfer Pricing Reporting Requirements in Israel
Happy Holidays! Wishing you and your loved ones health and happiness in the new year. May 2023 be an extraordinary
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Happy Holidays !
Dear Clients, Colleagues and Friends, The Tel Aviv District Court issued a new ruling in the tax appeal filed by
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Valuating IP that is Transferred Out of Israel – New Tel Aviv District Court Ruling
Dear Clients, Friends and Colleagues, On September 7th, the Finance Committee of the Knesset (the Israeli Parliament) finalized the approval
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Israel: Master File Requirements Finalized; Changes to Local File
Following on from our updates in March and April of this year, on June 14th, 2022 the Finance Committee of
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Finance Committee Approves Master File and CbCR Regulation Changes and other TP Requirements
Dear friends and colleagues, As a follow-up to our client update from February 16, 2021, we would like to update you that a
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New Directive Regarding Returned Exports and Temporary Entry
Meir Linzen
Chairman
Corporate Tax, Employee Tax Benefits, Gaming, Indirect Taxes, Customs & International Trade, International Tax Planning, Internet & E-commerce, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax, Tax Controversy – Disputes & Litigation, Transfer Pricing, Value Added Tax (VAT)
Eyal Bar-Zvi
Partner
Commercial, Hi Tech, International Tax Planning, Mergers & Acquisitions, Tax, Transfer Pricing
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