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Transfer pricing ("TP") tax implications should be regarded as a key factor, in relation to any cross border transaction. A re-llocation of income by any tax authority may cause significant tax liabilities and double taxation, in addition to a possible tax inspection by the Israeli ITA. It should be noted that the Israeli TP rules are under...
Over the last decade many Israeli residents have sought to settle previously unreported accounts of foreign - held assets and the income generated by them with the Tax Authority. This was typically performed by a formal petition to the Tax Authority via the Voluntary Disclosure Procedure. The procedure has changed over the years, has been extended periodically, and even allowed for submission of anonymous requests and negotiations until an arrangement was reached.
The Tax Authority has just published a tax ruling (decision 4429/19), about VAT obligations for services rendered to a foreign resident via operation and management of a website advertising products of foreign suppliers abroad that provides links (affiliation) to the supplier websites abroad for purchase. The taxation decision states that full VAT applies to income from these services despite the rule that a zero rate VAT applies to services provided to foreign residents.
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