Transfer Pricing

Whatever the nature of your business and whatever your industry, we have the tools, the local presence and the sophisticated, up-to-date regulatory knowledge to help you stay ahead of the TP game.

PwC Israel's Transfer Pricing Department is part of a global network with over 3,100 professionals in over 93 countries. We deliver coherent Transfer Pricing solutions that are responsive to the rapidly changing markets in which multinational corporations operate. Our team is well positioned to advise you on developing compliant, tax-efficient structures that help advance your business goals within the ever-shifting compliance landscape.

 

The experience accumulated both by our PwC Israel Transfer Pricing team and by our global network, allows us to effectively support you in any global transfer pricing project and to create globally aligned solutions that are both feasible and practical from a local perspective.

Our Services

• Develop global coordinated documentation in line with the new documentation requirements stemming from Action 13 of the OECD Base Erosion and Profit Shifting ("BEPS") project; including the Master File & Local File, as well as country-by-country ("CbC") reports

• Perform Value Chain Analysis, based on Actions 8-10 of the BEPS: Investigate into the functions, risks, assets and evaluate how they integrate with the group's key value drivers

• Develop coordinated transfer pricing documentation that takes into account the requirements of each jurisdiction

• Assist multinational entities to plan and implement local & global transfer pricing policies

• Perform benchmark analyses for all types of intercompany transactions including tangible, intangible & financial transactions

• Negotiate advance pricing agreements ("APAs") with tax authorities

• Support multinational entities during transfer pricing audits with local & foreign tax authorities

• Lead global dispute resolutions

• Evaluate reserves necessary for transfer pricing related uncertain tax positions (e.g., FIN48)

PwC’s global Transfer Pricing network has over two decades of delivering innovative, effective, forward-thinking solutions. Wherever you do business.

Contact us

Vered Kirshner

Vered Kirshner

Tax Partner, Head of International Tax cluster, PwC Israel

Tel: +972 3 7954849

Ben Blumenfeld

Ben Blumenfeld

Tax Partner, PwC Israel

Tel: +972 3 7954429

Eli Kaneti

Eli Kaneti

Senior Tax Manager, PwC Israel

Tel: +972 3 7954689

Michol Seror

Michol Seror

Senior Tax Manager, PwC Israel

Tel: +972 3 7954766

Lior  Ben Porat

Lior Ben Porat

Senior Tax Manager, PwC Israel

Tel: +972 3 7954586

Zaharit Ben-Shushan

Zaharit Ben-Shushan

Tax Manager, PwC Israel

Tel: +972 3 7955095

Marina Kayam

Marina Kayam

Tax Manager, PwC Israel

Tel: +972 3 7954724