Palestinian territories

Palestinian Income Tax Law does not mention group taxation.

Transfer pricing

Palestinian Income Tax Law does not mention transfer pricing; however, Article 15 of the Law, titled ‘Fraudulent Transactions’, might be applicable. Article 15 points 3 and 4 state that:

• If the tax assessor finds that a transaction is fraudulent or a sham, the assessor may disregard this transaction and assess tax on the concerned persons accordingly.
• If a non-resident person has conducted any work or activity or craft that is subject to tax according to the provisions of this Law by Decree with a resident person, and the tax assessor finds that the non-resident has control over the work activity to the extent that leaves the resident with no income or profit or with an income less than what could be earned, the tax shall be assessed on the basis of the actual profits to the non-resident person and he/she shall pay the tax. In the event of failure to pay the tax by the non-resident, the resident person shall be required to pay the tax on this basis.

Thin capitalisation

Palestinian Income Tax Law does not mention thin capitalisation.

Controlled foreign companies (CFCs)

Palestinian Income Tax Law does not mention CFCs.