Transfer pricing expert witness
As a well-recognized, prominent transfer pricing and international tax leader, Mr. Jacky Houlie leads our litigation support practice and serves as transfer pricing expert witness. With over 20 years of experience, Euromoney and the International Tax Review have consistently listed Jacky as a leading practitioner in the field. Jacky is the author of “Transfer Pricing”, […]
Legal implementation and Intercompany agreements
Legal implementation of transfer pricing & Intercompany Agreements In order to present a consistent structure of arm’s length pricing for a Group’s intercompany transactions, the transfer pricing documentation goes hand-in-hand with detailed intercompany legal agreements that reflects the contributions and value creation of the respective parties as well as a sound pricing mechanism consistent […]
Intercompany agreements
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Tax ruling & audit defense
Tax Ruling & Audit Defense / Transfer Pricing Expert Witness JH & Co. supports its clients in all aspects and interactions with respective tax authorities, including: Advanced Pricing Agreements (“APA”) Audit Defense Service Transfer Pricing Litigation Support Transfer Pricing expert witness Led by Mr. Jacky Houlie, formerly the head of Deloitte Israel’s transfer pricing controversy […]
supply chain optimization
Supply Chain Planning and Optimization Managing the complexities of a supply chain and improving efficiency and optimization of such, requires a constant finger on the pulse. Constant changes in business requirements and market dynamics, including the increasing digitation of global markets, necessitate effective uses of global supply chains. JH & Co. assists its clients in […]
ip valuations
IP Valuation and IP Migration analysis As the global economy continues to be driven by changes in technology, intellectual property is being evaluated for purposes of due diligence or transfers and migration of assets. Tax and transfer pricing regulations continue to focus on the economic and legal ownership and exploitation of intellectual property. At JH […]
transfer pricing documentation
Transfer Pricing Solutions for multinationals, spanning from start-ups to Fortune 500 enterprises: Comprehensive approach – tax, legal and economics Tax authorities worldwide have increasingly focused on transfer pricing to optimize their tax collection from multinational enterprises. Taxpayers are therefore required to be prepared for formal reviews and audits by respective tax authorities by establishing that […]
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Israeli Transfer Pricing Guidance on Business Restructuring
On November 1, the Israeli tax authorities published Circular 15/2018, entitled “Business Restructuring within a Multinational Group,” clarifying the Israeli government’s stance on the tax and transfer pricing aspects of changes in business models. In Circular 15/2018, the Israeli tax authorities outline techniques for identification and characterization of restructuring (including required disclosures), acceptable methodologies for assessing the […]
Israeli Tax Authorities Issue Transfer Pricing Circular Addressing Financial Transactions
On September 5, 2018, the Israeli Tax Authorities (“ITA”) published a number of circulars addressing Transfer Pricing (“TP”) issues: circulars 11/2018 and 12/2018 addressing distribution transactions and low value-added services (and adding safe harbors), respectively and Circular 13/2018, entitled: “Low-Interest Loans.” In Circular 13/2018, the Israeli Tax Authorities attempt to clarify various sections of Israeli tax legislation, […]