Controlled Foreign Company (CFC), Transfer Pricing & Group Consolidation
Anti Avoidance Provisions Tuesday, September 6th, 2011
Controlled foreign companies (CFC) The CFC rules are applicable to any foreign company controlled by Israeli Shareholders (50% of the shares) and that has accumulated undistributed passive income taxed at a rate below 20%. The Israeli shareholders will be assessed and taxed on their proportionate share of the undistributed income at a rate of 25%. [...]
