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Corporate Tax

26 June 2020
Anat Shavit Intercompany transactions – burden of proving arm's-length pricing

Israel - Fischer Behar Chen Well Orion & Co

The Israel Tax Authority (ITA) recently published a tax circular to clarify cases in which a transfer pricing study filed by a taxpayer will be considered to fulfil legal requirements and thus shift the burden of proof in the assessment process framework to an ITA inspector, in contrast to the general rule that the burden of proof rests with the taxpayer.

Authors: Anat Shavit, Uri Lampert
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