Israel

Overview of CbC reporting requirements

Israel has not yet introduced a requirement for the filing of CbC reports, as required under the BEPS Action 13 (CbC reporting) minimum standard.

Summary of recommendations

Area of implementation	Recommendations for improvement
Domestic legal and administrative framework	A review of Israel’s domestic legal and administrative framework will be included in the next peer review report.
Exchange of information framework	It is recommended that Israel take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which Israel has an international exchange of information agreement in effect that allows for the automatic exchange of tax information It is recommended that Israel take steps to implement the necessary processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.
Appropriate use	It is recommended that Israel take steps to ensure that the appropriate use condition is met ahead of the first exchanges of information.

The domestic legal and administrative framework

Israel’s 2020/2021 peer review report included a recommendation to take steps to implement legislation to impose a CbC reporting filing requirement. Israel has since introduced such a filing requirement but it has not been possible to carry out a review of this legislation. The recommendation to implement legislation is therefore removed and a review of the legislation will take place in the next peer review.

The exchange of information framework

Israel has no bilateral relationships in place for the exchange of CbC reports nor processes to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.

It is recommended that Israel take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which Israel has an international exchange of information agreement in effect that allows for the automatic exchange of tax information

It is recommended that Israel take steps to implement the necessary processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.

Appropriate use of CbC reports

Israel does not yet have controls in place to ensure the appropriate use of CbC reports.

It is recommended that Israel take steps to ensure that the appropriate use condition is met ahead of the first exchanges of information.