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On 1 November 2o18 the Israeli Tax Authority (ITA) published a circular providing its view regarding business restructuring of an Israeli entity that is part of a multinational group. The circular sets out the ITA's position on the identification and characterization of a business restructuring and, in the event that a business restructuring has occurred, the circular sets out the methods for performing a valuation of the functions, risks and/or assets (FAR) that have been terminated or transferred outside of Israel.

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