On 5 July 2021, the Israeli Ministry of Finance announced the approval of proposed amendment to the Transfer Pricing (TP) provisions of the Israeli Income Tax Ordinance (ITO). The amendment proposal introduces the three-tiered TP documentation requirements developed as part of the OECD BEPS project.
According to the announcement, the Country-by-Country (CbC) reporting requirement will apply for MNE groups if group revenue equal to or more than EUR 750 million. The amendment proposal would also require contemporaneous documentation to be submitted upon request by the tax authority.
