A CRITICAL TAX REQUIREMENT FOR INTERNATIONAL GROUPS
In today’s rapidly evolving global tax environment, transfer pricing has become a major compliance and strategic issue for multinational groups.
Tax authorities, including in Israel, France, the U.S., and across the EU require companies to justify the pricing of their cross-border intra-group transactions (goods, services, royalties, financing, etc.) under the arm’s length principle.
Failure to comply may result in:
• Significant tax reassessments
• Penalties for insufficient documentation
• Double taxation risks
ASSULINE & CO : YOUR TRANSFER PRICING STRATEGY PARTNER
With over 25 years of experience, Assuline & Co. supports Israeli companies and international groups in transfer pricing compliance, documentation, and strategic planning.
Our multidisciplinary team is well-versed in Israeli tax law, OECD guidelines, and the bilateral nuances of international tax treaties.
We work closely with your legal, financial, and international teams to deliver a cohesive, defensible, and secure strategy especially in the event of a tax audit.
OUR TRANSFER PRICING SERVICES
Intra-Group Flow Analysis
• Mapping of all intra-group transactions (goods, services, IP, loans, etc.)
• Identification of related tax risks
• Definition of a tailored transfer pricing policy
Documentation & Reporting
•Local File: detailed description of the Israeli entity functions, assets, risks
• Master File: group-level presentation, profit allocation, transfer pricing policy
• Benchmarking studies and comparability analysis
• Review and update of intercompany agreements
Audit Support
Preparation for Israeli Tax Authority (Mas Hachnassa) audits
• Technical and economic defense strategies
• Negotiation with authorities and defense of applied pricing methods
Strategic Advisory
Development or revision of group-wide transfer pricing policies
• Guidance on function location and value chain structuring
• Structuring advice for international flows: royalties, management fees, interest payments
WHO SHOULD USE THIS SERVICE?
Israeli subsidiaries of foreign parent companies
• International groups operating in Israel
• Israeli start-ups with foreign shareholders or investors
• Companies billing or receiving services from related foreign entities
• Holding companies or businesses with dividend, interest, or service transfers
WHY ASSULINE & CO?
• Full command of Israeli and OECD transfer pricing regulations
• Expertise across multiple sectors: tech, services, industry, e-commerce
• Multilingual team: French, English, Hebrew
• Thorough, confidential, and well-documented processes
• Preventive and defensive approach in case of tax audit
Contact us today for a confidential consultation
Audit your intra-group transactions and secure your transfer pricing strategy with confidence
Assuline & Co. Your strategic tax expert in Israel and internationally