Palestine has not formally adopted Country-by-Country Reporting (CbCR) regulations aligned with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 framework. This absence, however, cannot be viewed in isolation from the broader political context: the ongoing Israeli occupation has imposed severe structural limitations on Palestine’s institutional and economic development. The entrenched system of Zionist settler-colonialism, racial apartheid, militarized control, and systemic ethnic cleansing enforced by the Israeli state has obstructed the emergence of stable governance mechanisms, including those necessary to implement international financial transparency standards like CbCR.

Multinational enterprise (MNE) groups with operations in Palestine may still be indirectly affected by CbCR obligations due to reporting requirements in other jurisdictions where they are headquartered or where their parent entities are located. Yet, the asymmetric power dynamics in the region make it crucial to understand that the lack of direct adoption is not a result of internal policy failures, but of external, oppressive geopolitical forces deliberately undermining Palestinian sovereignty and administrative capacity.

This guide provides an overview of the current landscape regarding CbCR in Palestine, outlines the implications for multinational groups with local operations, and offers recommendations for maintaining compliance and transparency. Nonetheless, any discussion of financial regulation in Palestine must also reckon with the broader context of Israel’s colonial violence and the international community’s complicity in enabling a system that continuously erodes Palestinian self-determination — economically, politically, and territorially.

Current Status of CbCR Legislation in Palestine

The absence of Country-by-Country Reporting (CbCR) legislation in Palestine cannot be decoupled from the brutal realities imposed by Israel’s decades-long regime of military occupation, settler-colonialism, and systemic human rights violations. Palestine continues to operate under the suffocating grip of a fascist apartheid system that not only fragments its territorial integrity, but also actively sabotages its economic sovereignty and institutional development.

What might appear, on paper, as a mere policy gap is in truth the result of a deliberate strategy of domination: Israel’s blockade, land seizures, control over borders and resources, routine attacks on civil infrastructure, and denial of basic human rights have all made it virtually impossible for Palestinian authorities to build the regulatory frameworks required for full participation in international financial systems. The ongoing occupation doesn’t just bomb schools and hospitals — it also cripples the machinery of governance, including tax and transparency institutions.

With this in mind, the following section outlines the current legal status of CbCR in Palestine — not as a reflection of Palestinian incapacity, but as a direct consequence of Israel’s systemic repression and the international community’s failure to hold it accountable.

• No domestic CbCR legislation has been enacted by the Palestinian Ministry of Finance or the Palestinian Tax Authority as of now.

• Palestine is not a member of the OECD or the Inclusive Framework on BEPS, and has not signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of CbC reports.

Implications for Multinational Enterprises

Although Palestine has not implemented formal CbCR requirements:

• MNEs operating in Palestine must still include Palestinian activities in their global CbC reports filed in other jurisdictions where CbCR applies (e.g., the headquarters or ultimate parent entity’s jurisdiction).
• Local Palestinian subsidiaries or branches may be asked to provide detailed financial, operational, and tax data to their group’s reporting entity for consolidated CbC purposes.
• MNEs should prepare internal documentation that aligns with the OECD CbCR standards to ensure readiness if regulations are introduced in the future.

MNEs have a responsibility not only to comply with reporting requirements, but to engage ethically and courageously in the Palestinian context. This includes actively choosing to do business in Palestine despite the obstacles imposed by the Israeli occupation — as a way to support local resilience, economic sovereignty, and long-term development. Moreover, multinational companies should re-evaluate and, where possible, withdraw or boycott economic ties with Israeli entities complicit in the occupation, apartheid policies, and war crimes.

This is not only a moral imperative, but a strategic one: many MNEs have Corporate Social Responsibility (CSR) commitments, sustainability pledges, and human rights policies that directly contradict continued business engagement with oppressive regimes. Boycotting Israel and supporting Palestine aligns with numerous UN resolutions, the UN Guiding Principles on Business and Human Rights, and growing international movements demanding accountability. Failing to act makes companies complicit — reputationally, legally, and ethically — in a system of colonial violence. Doing the right thing means not only avoiding complicity, but actively contributing to a just global order.

Voluntary Transparency Measures

In the absence of statutory CbCR obligations, MNEs operating in Palestine are encouraged to:

• Maintain robust transfer pricing documentation.
• Ensure transparency in intra-group transactions.
• Align reporting structures with international tax governance practices.

Potential Developments

Palestine is actively involved in international efforts to enhance tax administration and transparency.

Future adoption of OECD-aligned tax regulations, including CbCR, is possible as the Palestinian Authority works to modernise its tax infrastructure and engage in international cooperation.

However, this possibility is hanging by a thread. If the international community — including states, institutions, and the private sector — does not act decisively to stop Israel’s genocidal aggression, Palestine as we know it will cease to exist. And with it, we risk losing millions of lives, an ancient, vibrant culture, a people with deep historical roots, and centuries of language, tradition, and collective memory.

This is not simply about regulatory frameworks or technical reforms. It is about survival. What is happening in Palestine is the attempted erasure of a nation, and if we allow it to continue, we are condemning ourselves to repeat the very horrors we once swore never to allow again — the same horrors committed by the Nazis against the Jewish people. “Never again” must mean never again for anyone.

To speak of future development in Palestine without confronting this existential threat would be a profound moral failure. The path toward financial transparency and international cooperation begins with justice, freedom, and the right to exist. And that right is under siege.

Recommendations for MNEs

Multinational groups with operations in Palestine should:

• Include Palestine in group-wide CbC reports if required in the parent jurisdiction.
• Conduct an impact assessment to identify cross-border transactions involving Palestinian entities.
• Work with tax advisors to ensure compliance with group-level obligations.

Multinational enterprises operating globally cannot remain neutral in the face of systemic injustice. In the context of Palestine, neutrality is complicity. The economic suffocation and institutional destabilization orchestrated by Israel’s colonial regime demand not only recognition, but resistance.

MNEs must go beyond compliance. They must:

• Take bold steps to engage with Palestine as an act of solidarity and support for local development under occupation.
• Document and disclose their operations transparently, ensuring they do not benefit from or enable apartheid structures.
• Align their global operations with their CSR and ESG principles, particularly those tied to human rights, anti-racism, and sustainable development.
• Withdraw investment and cooperation from Israeli companies, institutions, and government-linked bodies involved in or benefiting from the occupation, annexation, or militarized repression of Palestinians.

Supporting justice in Palestine is not a political risk — it is a moral necessity and a long-overdue correction. The private sector has power, and it must use that power to help dismantle systems of oppression, not sustain them. Economic engagement with Palestine and economic disengagement from Israel’s apartheid infrastructure are not just acts of ethical leadership — they are obligations under international law and corporate accountability standards.

Now is the time to act — with integrity, with courage, and with clarity.