On February 11, 2025, the Israeli Tax Authority issued a new Circular, which provides information on the amendments to the Income Tax Ordinance regarding transfer pricing and country-by-country (CbC) reporting requirements. Specifically, the circular details the filing obligations for multinational enterprise (MNE) groups with consolidated annual revenue exceeding 750 million euros (US$782.5 million). It specifies that CbC reports must be submitted in Israel if the MNE group’s ultimate parent is a resident, with certain exceptions. The circular also covers online filing processes, automatic exchanges of information between authorities, and the requirement to submit CbC reports within 12 months after the end of the parent entity’s tax year. Additionally, it addresses registration, reporting procedures, currency conversion rules, and penalties for noncompliance.
To access the Circular, click here.