Multinational groups operate within an increasingly complex environment of domestic and international tax laws, tax treaties, transfer pricing requirements, international reporting obligations and evolving global tax standards. Effective cross-border tax planning requires an understanding not only of the applicable tax rules, but also of the group’s business model, corporate structure and long-term commercial objectives.

Bracha & Co. advises multinational corporations, international groups and financial institutions on their activities in Israel, while also assisting Israeli corporations and business groups in establishing, expanding and managing operations abroad.

International Companies Entering the Israeli Market

The firm advises multinational groups and international financial institutions establishing or expanding their activities in Israel.

Our work includes structuring Israeli operations, establishing local entities, designing holding and financing structures, analyzing permanent establishment exposure, withholding taxes, treaty eligibility and the broader Israeli tax implications of the proposed activity.

Where appropriate, Bracha & Co. approaches the Israel Tax Authority prior to commencement of the activity in order to obtain advance tax rulings (Pre-Rulings) and other approvals, providing greater tax certainty regarding the treatment of the proposed structure and operations.

Israeli Corporations Expanding Abroad

Bracha & Co. advises Israeli companies and corporate groups establishing or expanding international operations, including the formation of foreign subsidiaries and entities, international holding structures, financing arrangements, cross-border movement of funds and profits, and the Israeli tax implications of foreign activities.

Our advice is based on the overall structure and commercial objectives of the group, taking into account Israeli taxation, the laws of the relevant foreign jurisdictions and applicable tax treaties.

BEPS, Transfer Pricing & Intercompany Transactions

The firm advises multinational groups on Base Erosion and Profit Shifting (BEPS) principles and their impact on international structures, allocation of profits, economic substance, documentation and cross-border arrangements.

We also advise on transfer pricing matters and intercompany transactions, including management fees, royalties, financing arrangements, allocation of income and expenses and other transactions between related entities.

Our work further encompasses corporate residency, management and control, permanent establishments, cross-border income and the application of double tax treaties.

Complex Tax Arrangements & Representation Before the Israel Tax Authority

Bracha & Co. has extensive experience representing multinational corporations and international groups in negotiations with the Israel Tax Authority and in developing complex tax arrangements.

This includes long-term arrangements designed to provide tax certainty and, where applicable, access to significant tax incentives and benefits available under Israeli law.

The firm manages the process from the development of the tax structure and professional position through discussions and negotiations with the relevant departments of the Israel Tax Authority, and ultimately through implementation of the ruling or agreed tax arrangement.

Local Representation in Israel

In addition to tax advice, Bracha & Co. provides international companies and financial institutions with a broad local support platform for their activities in Israel.

Where appropriate, the firm acts as the company’s local representative and assists international management teams in their interactions with the Israel Tax Authority, banks, regulatory bodies and other Israeli institutions.

As part of long-term engagements with international groups, members of the firm may also serve as directors of Israeli companies, providing an additional level of familiarity with the group’s activities and ongoing requirements in Israel.

The ability to advise both international groups entering Israel and Israeli corporations expanding into global markets, combined with our experience in international taxation, financial institutions and negotiations with the Israel Tax Authority, enables Bracha & Co. to provide comprehensive tax and legal support for sophisticated cross-border operations.

For advice on multinational corporate taxation and cross-border business activities, please contact Bracha & Co.