Israel: Guidelines on CbC report submissions for multinational enterprises

Circular 01/2025 mandates country-by-country reports be filed in the ultimate parent entity's country, with provisions for surrogate filing under specific conditions.

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April 22, 2025

The Israeli tax authority (ITA) in February 2025 issued Income Tax Circular 01/2025, detailing guidelines for multinational enterprises on country-by-country (CbC) report submissions.

The circular mandates CbC reports be filed in the ultimate parent entity's country, with provisions for surrogate filing under specific conditions.

Israeli entities must notify the ITA if filing abroad, and local filing is required if no exchange treaty exists. Noncompliance is penalized, and accurate reporting is crucial due to implications under the OECD's global minimum tax framework.


For more information, contact a KPMG tax professional in Israel:

Yehuda Yarm | yyarm@kpmg.com

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