The Israel Tax Authority (ITA) has published guidance on the submission of Country-by-Country (CbC) reports. As previously reported, Israel has introduced a CbC reporting requirement for MNE groups meeting a consolidated revenue threshold of ILS 3.4 billion that apply from the 2022 reporting fiscal year, with reports due within 12 months following the end of the year. However, companies may also submit a CbC report in Israel for the 2021 reporting fiscal year, which is due by 31 March 2023.
The guidance covers the timing of the requirements as well the method of submission. This includes that in order to submit a CbC report in Israel, registration is required in a dedicated Internet system, the HMA portal for automatic exchange of information. This system may be used by Israeli ultimate parent entities submitting their CbC report in Israel as well as foreign ultimate parent entities that wish to submit its CbC report in Israel. The guidance also notes that an Israeli ultimate parent entity may choose to submit the CbC report in another country where a group entity exists. In this case, the ultimate parent must report on where the CbC report will be submitted.
Lastly, the guidance provides that where a constituent entity resident in Israel is not the ultimate parent entity, it must report on the country in which the CbC report is submitted together with identifying details including the name of the entity, the number of the entity, the name of the multinational group, the name of the ultimate parent entity, tax identification number, and contact information. For this purpose, the information is submitted via email to IsraelCBCrLFN@taxes.gov.il.
Technical instructions for the purpose of CbC reporting have also been published.
Questions regarding CbC reporting in Israel can be set to IsraelCBCr@taxes.gov.il.