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Transfer Pricing

Transfer Pricing

The term "transfer pricing" relates to international transactions performed between related parties, and covers all sorts of transactions, the most common being distributroship, R&D, marketing, manufacturing, loans, management fees, and IP licensing.

All intercompany transactions must be regulated in accordance with applicbale Israeli (or other) law, and comply with the "arm's length" principle, which requires holding an updated transfer pricing study and an intercompany agreement based upon the study.

Some corporations perform their intercompany transactions based upon previously issued studies or an ill based advice they have received, to work at a “cost plus X%”. This is not sufficient. Such a decision has to be supported, in terms of methodology and amount of overhead, by a proper transfer pricing study, and it has to be updated each financial year.

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