Last Saturday October 8, 2023, Southern Israel and the world witnessed appalling acts of acts of wanton savagery unprecedented since the Holocaust – thousands of dead, injured and abducted civilians. Our hearts go out to the affected people, their families…

The Israeli government published a bill on September 6, 2023, which aims to tighten up Israeli rules for taxing offshore controlled foreign companies (CFCs) and foreign professional companies (FPCs). The Israeli proposals have echoes of US GILTI (global intangible low-taxed…

The Israeli government wants to take a different bite out your apples (and income) abroad – but not for new Olim. The government published on September 6 two draft bills to reform international tax rules in Israel – one concerning…

The OECD has quietly issued a far-reaching Public Consultation Document on streamlining the taxation of intercompany “baseline marketing and distribution activities” within multinational groups. Because there is apparently no size limit, these proposals, if adopted, could shake up Israeli and…

The Israeli Tax Authority (ITA) has issued Circular 1/23 on August 17, 2023 (back-dated to February 12, 2023) on the process for requesting bilateral agreement between the ITA and the tax authority of another country under a tax treaty. Israel…

The District Court has rejected a class action against the Israeli Tax Authority (ITA) that allegedly made Israeli banks withhold excess tax at source from dividends from abroad (Yaacov Hostatzky  vs. ITA, 20739-06-21, handed down May 14, 2023 by Judge…

Hitech founders often dream of an exit (M&A deal). How does a tech company exit (M&A deal) at a good price? A corporate auction may sometimes improve the starting price, but how does a seller company get to the best…

An Israeli court has ruled that if a foreign group buys the shares of an Israeli tech start-up, strips out the IP (intellectual property) and terminates the Israeli company, the company must pay tax on the IP stripped out (Medtronic…

The budget law has now passed the Knesset. It contains various measures relating to e-invoice numbers, small businesses, rental income taxed at 10% and much more. Below is a review of some income tax and VAT measures (Economic Efficiency Law…

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…