Category: Israeli Corporate Tax Planning

27

May2023
The Israeli Tax Authority (ITA) has issued instructions for the non-taxation of SAFEs (Simple Agreement For Future Equity). A SAFE has become a popular way of financing hitech start-ups in the last few years so non-taxation instructions are important. The instructions weren’t passed by the Knesset, they were issued in ... Read More
May 27, 2023Leon Harris

27

May2023
The Israeli Supreme Court has just ruled when an M&A deal (merger & acquisition or “exit” deal) is considered done and which resulting exchange rate should be used to report the deal for Israeli capital gains tax purposes. Background: The Israeli shekel has its ups and downs, so exchange rates matter. Many M&A ... Read More
May 27, 2023Leon Harris

27

May2023
The term “treaty shopping” means using a company which just happens to be incorporated in a country which has a favorable tax treaty with another country, such as Israel. In a recent District Court, a BVI (British Virgins Island) company with a branch in Israel was owned by a BVI parent ... Read More
May 27, 2023Leon Harris

27

May2023
Governing the Israeli people has always been difficult, but the proposed changes to the judicial system are proving especially challenging and divisive. The people are split down the middle, Israel’s economy and credit rating may or may not be affected, and the world is looking on. So what are the ... Read More
May 27, 2023Leon Harris

27

May2023
The Israeli tax return filing season has started…. Who must file a tax return? In principle, persons required to file an annual Israeli tax return include: (1) Israeli resident individuals over 18 unless they are eligible for a filing exemption (see below); (2) most trusts with an Israeli connection; (3) Beneficiaries  who ... Read More
May 27, 2023Leon Harris

27

May2023
In the hitech world, you are only as good as your last few start-ups. So if 80% of them are being set up outside of Israel, the Israeli economy may be on borrowed time..... The Israel Innovation Authority has published a Position Paper (“Concern About Disintegration of Israeli Hitech Due To ... Read More
May 27, 2023Leon Harris

19

Mar2023
President Herzog presented his draft “People’s Plan” for judicial reform on March 15, 2023. But within minutes it was rejected by the government. You can read the draft plan in English here: https://www.mitve-haam.org/ (scroll down and click on “The People’s Directive”). We consider below some of the anticipated consequences for ... Read More
March 19, 2023Leon Harris

19

Mar2023

What is a Business?

The Israeli Supreme Court has ruled that a meat trader who also carried out some real estate transactions was in business, resulting in a hefty extra VAT liability of NIS 825,000. This was a VAT case but it is fair to assume the taxpayer, an individual, may have also paid ... Read More
March 19, 2023Leon Harris

19

Mar2023
Following the recent surprise collapse of Silicon Valley Bank (SVB), a leading bank for the high tech sector, a number of Israeli companies have apparently experienced short term cash flow difficulties. This is despite the announcement of March 12 from US Federal Reserve Bank offering full cover for holders of ... Read More
March 19, 2023Leon Harris

19

Mar2023
As if we Israelis don’t have enough on our plate, an important Supreme Court case tells us what is food and how much can be assessed to 17% VAT if meals are provided at work. The income tax and national insurance authorities are expected to follow suite.  In short, will ... Read More
March 19, 2023Leon Harris