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
Tax Partner
Tel: +972 3 7954849

Eli Kaneti
Senior Tax Manager
Tel: +972 3 7954689

Michol Seror
Senior Tax Manager
Tel: +972 3 7954766

Ben Blumenfeld
Senior Tax Manager
Tel: +972 3 7954429

Lior Ben Porat
Tax Manager
Tel: +972 3 7954586

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