Israel: Guidance on competent authority, mutual agreement, and bilateral APA procedures

Replaces guidance previously released in 2001

Replaces guidance previously released in 2001

The Israel Tax Authority (ITA) on 17 August 2023 published Tax Circular 1/2023 clarifying the relevance and procedures for competent authority, mutual agreement and bilateral advance pricing agreement (APA) requests.

The circular, which replaces guidance previously released in 2001, enumerates the scenarios that may be relevant for Israel taxpayers in seeking treaty-based relief from potential double tax and outlines the expected process and requirements for such an application.

Read an unofficial translation of Tax Circular 1/2023 [PDF 148 KB]

For more information, contact a tax professional with the KPMG Global Transfer Pricing Services practice in Israel:

David Samson | +(972) 3 684 8970 |

Itay Falb | +(972) 3 684 8000 |



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