Israeli Tax Authority releases final circular on payments to a parent company under cross-border recharge agreements for grant of stock-based compensation

Executive summary
The Israeli Tax Authority (ITA) has published the final circular (the Circular) regarding payments to a parent company under recharge agreements for the grant of stock-based compensation (SBC). This follows a draft circular (the Draft Circular) that was published by the ITA in March 2020.1
The purpose of this Circular is to outline the ITA’s position with respect to the interc…