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Transfer pricing

Transfer pricing is a term used to describe inter-company pricing arrangements relating to transactions between related entities.


Transfer pricing are subject to scrutiny by tax authorities, and for compliance with tax regulations, the taxable profit of the taxpayer should be determined applying the "arm's length" principle.


Documentation on transfer prices is submitted to the Tax Authority, and the obligation to prepare transfer pricing documentation covers resident taxpayers who, during the tax period, engaged in transactions with non-residents, as well as relationships between resident related parties in cases where one of the related parties has:

  • privileged tax status, meaning they pay corporate income tax at rates lower than the prescribed rate or are exempt from paying corporate income tax,

  • the right to carry forward tax losses from previous tax periods.


Our team provides comprehensive transfer pricing documentation services, regardless of the size of the company. We prepare all documentation in accordance with local tax regulations and OECD guidelines.

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