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Israel - Stock-Based Compensation and the Arm’s Length Principle

Country:
Israel
Author:
S. Hubscher; J. (Jacky) Houlie
Issue:
International Transfer Pricing Journal, 2018 (Volume 25), No 5
Published:
22 August 2018
This article will explain the background and the accounting/tax implications of stock-based compensation (SBC) and its context within transfer pricing (TP) and the arm’s length principle. More specifically, the article will focus on the inclusion of SBC in the cost base for TP purposes. Legislation and judicial decisions regarding SBC are raised and considered and, finally, the article provides alternative approaches to TP methodologies for SBC.
 
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