Category: General Tax

01

Oct2023
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 foreign tax credits, the other concerning controlled foreign companies (CFCs) and ... Read More
October 1, 2023Leon Harris

01

Oct2023
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 international routine trade and tax across the 143 countries signed up ... Read More
October 1, 2023Leon Harris

24

Aug2023
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 has income tax treaties with 61 countries including the US, ... Read More
August 24, 2023Leon Harris

24

Aug2023
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 Y. Saroussi). Main Facts: The case concerned an Israeli resident private individual ... Read More
August 24, 2023Leon Harris

24

Aug2023

About Exits

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 starting price in the first place? And what are potential buyers ... Read More
August 24, 2023Leon Harris

24

Aug2023
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 Vs. Kfar Saba Assessing Officer, District Court Civil Appeal 31671-09-18, ... Read More
August 24, 2023Leon Harris

24

Aug2023
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 (Legislative Amendments To Achieve Budgetary Goals for Budget Years 2023-2024), ... Read More
August 24, 2023Leon Harris

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