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March 15, 2021

Thursday, 25 March 2021 | BorderCrossings . . . With EY transfer pricing and tax professionals (1 pm ET)

Latest transfer pricing (TP) news about Israeli TP controversy and reclassification of recharge payments

The change in the Israeli tax landscape relating to the Israeli Tax Authority (ITA)’s approach to TP is causing multinational entities (MNEs) to evaluate their TP positions and prepare for potential tax controversy in Israel. Israel continues to position itself in the tech industry as an innovation and research and development (R&D) hub, which is causing: (1) increased merger and acquisition (M&A) activity in which MNEs acquire Israeli companies and (2) a high number (more than 300) of MNE R&D centers in Israel. As a result, the ITA increasingly focuses on MNEs’ TP positions for their M&A activity and R&D centers in Israel.

This webcast will feature an update on TP controversy in Israel from Ernst & Young LLP (US) and Ernst & Young (Israel) Ltd TP and International Tax professionals. Topics will include:

  • The ITA application of the profit split method to R&D centers and the potential implications for intellectual property ownership following the Organisation for Economic Co-operation and Development’s (OECD) ongoing work on this topic
  • Updates on the ITA’s digital economy agenda
  • The ITA’s recently published tax circular on classifying payments under recharge agreements for stock-based compensation grants and how companies are responding

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

Date: Thursday, 25 March 2021

Time: 1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver

Registration: Register here.


  • Sharon Shulman, Head of Tax, Ernst & Young (Israel) Ltd
  • Lior Harary-Nitzan, International Tax and Transaction Services, Ernst & Young (Israel) Ltd
  • Yaron Kafri, 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: 1.4. Recommended field of study: Taxes. Learning objective: Understand and be able to explain recent transfer pricing controversy developments in Israel related to recent M&A trends and Israel’s emergence as a tech and innovation hub. This intermediate level, internet-based group 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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The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


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