FBC Tax Update: Intercompany transactions – burden of proving arm's-length pricing

By Anat Shavit & Uri Lampert | Jun 2020 | Legal Update

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.

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