In today\u2019s rapidly evolving global tax environment, transfer pricing has become a major compliance and strategic issue for multinational groups.
\nTax 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\u2019s length principle.
\nFailure to comply may result in:
\n\u2022 Significant tax reassessments
\n\u2022 Penalties for insufficient documentation
\n\u2022 Double taxation risks<\/p>\n
With over 25 years of experience, Assuline & Co. supports Israeli companies and international groups in transfer pricing compliance, documentation, and strategic planning.
\nOur multidisciplinary team is well-versed in Israeli tax law, OECD guidelines, and the bilateral nuances of international tax treaties.
\nWe 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.<\/p>\n
\u2022 Mapping of all intra-group transactions (goods, services, IP, loans, etc.)
\n\u2022 Identification of related tax risks
\n\u2022 Definition of a tailored transfer pricing policy<\/p>\n
\u2022Local File: detailed description of the Israeli entity functions, assets, risks
\n\u2022 Master File: group-level presentation, profit allocation, transfer pricing policy
\n\u2022 Benchmarking studies and comparability analysis
\n\u2022 Review and update of intercompany agreements<\/p>\n
\u2022 Preparation for Israeli Tax Authority (Mass Hachnassa<\/em>) audits \u2022 Development or revision of group-wide transfer pricing policies \u2022 Israeli subsidiaries of foreign parent companies \u2022 Full command of Israeli and OECD transfer pricing regulations Contact us today for a confidential consultation. Assuline & Co. Your strategic tax expert in Israel and internationally.<\/p>\n","protected":false},"excerpt":{"rendered":" Secure your cross-border intra-group transactions<\/p>\n","protected":false},"author":1,"featured_media":3592,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-3802","page","type-page","status-publish","has-post-thumbnail","hentry"],"yoast_head":"\n
\n\u2022 Technical and economic defense strategies
\n\u2022 Negotiation with authorities and defense of applied pricing methods<\/p>\nStrategic Advisory<\/h3>\n
\n\u2022 Guidance on function location and value chain structuring
\n\u2022 Structuring advice for international flows: royalties, management fees, interest payments<\/p>\nWHO SHOULD USE THIS SERVICE?<\/h2>\n
\n\u2022 International groups operating in Israel
\n\u2022 Israeli start-ups with foreign shareholders or investors
\n\u2022 Companies billing or receiving services from related foreign entities
\n\u2022 Holding companies or businesses with dividend, interest, or service transfers<\/p>\nWHY ASSULINE & CO?<\/h2>\n
\n\u2022 Expertise across multiple sectors: tech, services, industry, e-commerce
\n\u2022 Multilingual team: English, Hebrew, French
\n\u2022 Thorough, confidential, and well-documented processes
\n\u2022 Preventive and defensive approach in case of tax audit<\/p>\n
\nAudit your intra-group transactions and secure your transfer pricing strategy with confidence.<\/p>\n