- Transfer pricing study
Our firm has an unmatched 100% success rate in tax audits worldwide for its transfer pricing studies, and was nominated is Israel's best transfer pricing team for 2011. Founded in 2006, we have filed and defended already hundreds of transfer pricing studies all around the globe, for Israeli and foreign multinationals.
Every transfer pricing study performed by our firm gets the full attention of our partners, who is also responsible for the drafting of the intercompany agreement, which consists an integral part of the documentations requirements of applicable transfer pricing regulations.
Bar-Zvi & Ben-Dov is the Israeli partner of Transfer Pricing Associates, an international network of independent transfer pricing experts, with branches in over 40 countries. Through this alliance, we are able to actually provide our clients with assurance and signoffs in each and every jurisdiction in which they are active.
- Intercompany agreement
Any intercompany transaction must be accompanies by an agreement, which is based upon the results of the transfer pricing study and the analysis performed as part of the study. In some countries, the subsidiary cannot start operating without an intercompany agreement in place.
On the other hand, an intercompany agreement in itself, without the accompanying study, does not suffice, and an agreement which is not in line with the study, in terms of pricing, methodologies and functions, is an exposure in itself.
Our firm, which was founded by attorneys who also hold degrees in economics and finance, is unique in this field, providing its clients with both the study and the intercompany agreement, as one holistic package, which also includes the implementation of the study's results.
- Transfer pricing policy (SOP)
In larger firms, with more than several subsidiaries, it is recommended to adopt a transfer pricing policy, which is drafted in the form of a standard operating procedure, and which guides the company on all its intercompany transactions. Additionally, this is highly recommended – and practically required – for any multinational which is a public company, operating under SOX or similar rules (such as the FIN48 requirement), including those applicable in Israel.
- Intercompany finance
Intra-group funding arrangements have long been used as means for centralization of a group’s cash and currency, as a mean to control and risk management, and as the preferable way to fund certain transactions or the incorporation of new subsidiaries within the group. Recently, the transfer pricing aspects of intercompany financial arrangements have come under detailed and ever growing scrutiny. Under current legislation and rules, from a tax and transfer pricing perspective, financial arrangements between related parties must be transacted on an arm’s length basis, taking into account the parties' ability to receive funding or guarantees in the market.
Our services in this respect range from a review of interest or guarantee charges, through supplying supporting documentations, and to designing a transfer pricing policy (in the form of an SOP) which will support your group’s treasury policies.
- Transfer pricing valuations
Valuation of tangible and intangible assets can have a significant impact on the group’s decision making processes and business plan. When transferring assets within or outside a group, it is essential to have an economically robust valuation to support the transfer values.
Bar-Zvi & Ben-Dov, as part of the TPA Valuations global network, is able to provide you with valuation knowledge and expertise in respect of intercompany transactions, in accordance with IFRS and other international accounting standards.
From a transfer pricing perspective, the correct valuation of a tangible or intellectual property in accordance with the arm’s length principle, has become an integral part in any intercompany property transfer.
- Advance Pricing Agreements
An Advance Pricing Agreement is a sort of a pre-ruling, or an advance agreement with the tax authorities, on an appropriate transfer pricing methodology for one or more transactions, for a fixed period of time. This is achievable in several countries, including in Israel, and can be either unilateral (i.e. in one country) or bi-lateral (with both tax authorities involved), when applicable tax treaties exist.
An advance pricing agreement does not mean the company will not be audited, but rather that the tax authorities will not question the transfer pricing methodology used by the company, and is thus recommended mainly for large or complex transactions.