Introduction
This article provides a high-level overview of some of the common business models used by local entities that are engaged in the distribution, sale and marketing of their group s products and analyses the potential transfer pricing ramifications thereof.
The transfer pricing analysis included in this article is predominantly based on Circular 11/2018 (Determination of the appropriate transfer pricing method for activity related to distribution, marketing and sales of a multinational group within the local market),(1) published by the Israeli Tax Authority (ITA). Circular 11/2018 implements the Organisation for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (OECD guidelines).