Bar-Zvi & Ben-Dov have merged with Herzog Fox & Neeman, Israel's leading law firm.
For information about Eyal Bar-Zvi and his new contact details, please click here.
Our Services / Transfer Pricing
Bar-Zvi & Ben-Dov offers Israel’s most comprehensive guidance on international transfer pricing. The firm’s outstanding command of global requirements has resulted in a 100% acceptance rate of its studies by worldwide tax authorities, a position that is unmatched by any other firm. We act as a transfer pricing "one stop shop", providing our clients with country-specific preparation of the required studies, intercompany agreements, tax planning, economic implementation, and the formulation of transfer pricing policy. The firm was recently chosen to be the Israeli member of the worldwide group Transfer Pricing Associates.
To read more about Transfer Pricing please use the links to the left or refer to our informational website: www.transferpricing.co.il
Choosing The Right MethodologyThe days of plainly working on a "cost plus" basis, with an arbitrary overhead figure without taking into account all the required aspects and factors are long gone. Today, both international and local legislation dictate that the corporation has to choose the transfer pricing methodology which best suits its operations, pending the exact nature of the tested transaction, and subject to the applicable rules (which may differ).
When regulating transfer pricing, several different methodologies may be used. The tax payer should choose the applicable methodology with extra care, as different methodologies may lead to different legal and economic outcomes. For example, certain tax authorities may perceive a "cost plus" methodology as relevant only for a specific kind of transaction, while the "profit split" method should be applied to other kinds of transactions. Choosing the wrong kind of methodology may send a message to the tax authorities that the true nature of the intercompany transaction differs from the one stated by the company. In several countries, this may further result in determining that the company is a "Permanent Establishment".
For more information about the different methodologies, please refer to this page on our (Hebrew) transfer pricing website.