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Israeli court sides with Broadcom, concludes that business restructuring does not trigger tax
Jacky Houlie, of JH & Co. Law Office, and Shlomo Hubscher, of JH Consulting Ltd, discuss a landmark decision of Israel’s Lod District Court, released last week, which rejected the tax authorities’ position on the classification of Broadcom Israel’s business restructuring from a tax and transfer pricing perspective . . .
Asia-Pacific
Asia-Pacific
Americas
Asia-Pacific
Israel Supreme Court rules stock-based compensation must be added to cost base for transfer pricing
Shlomo Hubscher and Jacky Houlie of JH & Co. Law Office analyze an April 22 Israel Supreme Court decision which concluded that companies that use the cost plus transfer pricing method must include stock-based compensation in the cost base, thus increasing the taxes paid by many multinational firms with research and development operations in Israel . . .
Asia-Pacific
Asia-Pacific
Asia-Pacific
Asia-Pacific
Asia-Pacific
Africa
Asia-Pacific
Americas
US-Israel FATCA agreement enters into force
The US Treasury has announced on its website that the US-Israel Model 1 FATCA intergovernmental agreement (IGA), signed by the countries on June 30, 2014, entered . . .
Asia-Pacific
Asia-Pacific
Americas
Americas
Canada, Israel sign tax treaty, text available
Asia-Pacific
Africa
Switzerland consults on introducing automatic exchange of tax information with 22 countries
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
Asia-Pacific
Tax treaty requires Netherlands to extend fiscal unity regime to Dutch companies owned by foreign parent, court rules
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a Dutch Court of Appeal decision which requires the Netherlands to extend its fiscal unity-regime to Dutch companies that have foreign parents resident in Israel or resident in countries that have a tax treaty with a nondiscrimination clause similar to that in the Netherlands/Israel tax treaty. . .
Americas
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Americas
Asia-Pacific
Asia-Pacific
Asia-Pacific
Asia-Pacific
Israel’s new deemed distribution rules – a trap for the unwary multinational taxpayer
Yuval Navot and Ronen Avner of Herzog Fox & Neeman, Tel Aviv, analyze a tax department circular, published August 23, which interprets new Israeli deemed distribution rules in a draconian manner, making it required reading for multinational taxpayers operating in Israel that extend intercompany loans or guarantees . . .
