GLOBAL strategy for minimizing the overall tax burden
In the absence of careful planning, gains and income from operations outside Israel could be subject to considerable tax liabilities. We place special emphasis not only on minimizing the local Israeli tax burden but also on reducing the total effective tax rate. Our services focus on the review of the client holding structures, tax implications of the place of operation, the origin of income, and tax liability upon the distribution of profits, for the development of a comprehensive tax strategy for minimizing the overall tax burden. The Department has extensive knowledge concerning worldwide tax laws and the variety of tax benefits available under Israeli domestic laws.
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TP requirements mainly apply to cross-border transactions. If a multinational group establishing, merging or acquiring a subsidiary abroad, and that subsidiary makes transactions with other group companies (or with family members or significant shareholders), the prices applied in those transactions may directly affect how the profit or loss is measured, and it is important to disclose how those prices are set. A taxpayer’s CIT (corporate income tax) base should include in addition to his profit distributions also deemed distributions. Any income gained from related-party transactions must not be below market value and relevant expenses must not be above market value. Any resulting deficit or surplus must be included in the CIT base.
TP documentation – provides information necessary to describes the taxpayer’s business activities and the nature of related-party transactions to identify risks and assess the taxpayer’s compliance with regulations. We offer support in Identifying TP requirements assessing whether the company has any related-party transactions and what amounts are involved. to work out the total value of related-party transactions to be reported and understand whether the client is required to prepare TP documentation.
New immigrants and returning residents can receive significant tax benefits and support via the Ministry of Aliyah and Integration and the Tax Authority.
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