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February 19, 2020

Thursday, 27 February | BorderCrossings ... With EY transfer pricing and tax professionals (1 pm ET)

Latest Israel transfer pricing controversy news and updates on Israel's IP box regime and acquisition structures

The rapid change in the Israeli tax landscape and the continuous development of adjusted positions by the Israeli Tax Authority (ITA) require multinational entities (MNEs) to thoroughly build and support their own transfer pricing positions and be better prepared for tax controversy in Israel. As Israel continues to position itself in the tech industry as an innovation and research & development (R&D) hub, two major phenomena have occurred: (1) more intensive mergers and acquisitions (M&A) activity in which MNEs acquire Israeli companies, and (2) a higher volume (more than 300) of MNE R&D centers being located in Israel. As a result, the ITA is increasingly focused on MNEs' transfer pricing positions related to their M&A activity in Israel and the R&D centers that MNEs have in the country.

This webcast will feature an update on transfer pricing controversy in Israel from EY US and EY Israel transfer pricing and international tax professionals. The panelists will also discuss Israel's intellectual property (IP) box regime. Topics will include:

  • The latest post-acquisitions business restructuring court cases, as well as the ITA circular on this matter, with a comparison of their various features
  • The ITA's evolving position on the application of the taxation of R&D centers, which follows the ongoing work of the Organisation for Economic Co-operation and Development on this topic, and the potential impact it might have
  • The IP box regime and its unique features (e.g., its application to the private equity and pharmaceutical industries, nexus formula flexibilities), as well as its practical application
  • Updates on the ITA's digital economy agenda, which adopts the significant economic presence and digital permanent establishment concepts and seeks to broadly apply value-added tax liabilities to digital service providers
  • The Israeli Supreme Court holding on stock-based compensation inclusion for cost-plus purposes and what companies are doing to mitigate its effect
  • Updates on acquisition structures and repatriation strategies

We hope you will be able to join us for this important webcast.

Date: Thursday, 27 February 2020

Time: 1:00-2:15 p.m. EST New York/Toronto; 10:00-11:15 a.m. PST Los Angeles/Vancouver

Registration: Register for this event.


Sharon Shulman, Head of Tax, Ernst & Young (Israel) Ltd

Lior Harary-Nitzan, International Tax and Transaction Services, Ernst & Young (Israel) Ltd

Eyal Gonen, Transfer Pricing, Ernst & Young (Israel) Ltd

Lital Haber, Israel Tax Desk, Ernst & Young LLP (US)


Mike McDonald, Transfer Pricing, Ernst & Young LLP (US)

CPE credit offered: 1.5. Recommended field of study: Taxes. Learning objective: Understand the overall transfer pricing controversy in Israel. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling, and length of participation. See CPE FAQ for more information.

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