As previously reported, the Israeli Knesset (parliament) approved legislation on 30 June 2022 for the introduction of the three-tiered transfer pricing documentation requirements of BEPS Action 13. This includes:
- Country-by-Country (CbC) reporting requirement for MNE groups meeting a consolidated revenue threshold of ILS 3.4 billion;
- Stricter transfer pricing documentation requirements in line with the OECD Local file guidelines; and
- A Master file requirement for members of MNE groups with t…