Pension contributions are important in providing for our retirement years. Below is a brief overview of Israeli tax law rules for 2018.
Types of Members
The tax law distinguishes between “Privileged” and “Non-privileged” members of a provident fund, who may also be employed or self-employed.
A privileged member is one who contributes at ... Read More
Category: International Tax Planning
22
Oct2018
In October 2018, the ITA published a new fast track procedure for cases where the shareholders of an Israeli company wish to flip it. That means putting a foreign parent company (“ParentCo”) above the Israeli company. This happens quite often, especially in the hitech sector.
For example, a US pension fund ... Read More
October 22, 2018Leon Harris
22
Oct2018
The Israeli Tax Authority has just backed down on a problematic reportable tax position for certain investment funds. But the underlying tax exposure remains.
What is a Reportable Tax Position?
A reportable income tax position is a position contrary to a position published by the ITA by the end of the year concerned if the tax advantage exceeds NIS 5 million in the tax year ... Read More
October 22, 2018Leon Harris
22
Oct2018
The Israeli Supreme Court has just turned down not once but twice an appeal against the refusal of the District Court to allow a foreign tax credit in a case involving a US LLC. The result is double taxation. The taxpayer is upset. What went wrong?
Background:
A Limited Liability Company (LLC) ... Read More
October 22, 2018Leon Harris
17
Sep2018
The Israeli Tax Authority (ITA) has issued a new generic Ruling allowing a streamlined procedure for B2B (business to business) e-commerce supplies by foreign businesses to Israeli businesses (Ruling 6369/18).
The tax or lack thereof on e-commerce is a hot topic. On June 21 this year, the US Supreme Court ruled in the ... Read More
September 17, 2018Leon Harris
17
Sep2018
If have a skeleton in your closet and need an Israeli tax amnesty, you have only three months until the end of 2018 to request it on an anonymous basis from the Israeli Tax Authority. And it takes time to prepare.
Anyone applying for tax amnesty in 2019 will be at ... Read More
September 17, 2018Leon Harris
11
Jul2018
The Israeli Supreme Court has just ruled that a taxpayer cannot claim a foreign tax credit under the US-Israel tax treaty (Tel-Aviv 4 Assessing Officer vs. Gmul America Ltd, Civil Appeal 8934/16 of June 11, 2018).
Double taxation and no tax treaty relief is not good for international trade and investment ... Read More
July 11, 2018Leon Harris
08
May2018
On 21 March 2018, the European Commission proposed new rules to ensure that digital business activities are taxed in a “fair and growth-friendly” way across the EU.
This followed an OECD report of March 16 revealing a lack of international consensus about taxing digital operators (Tax Challenges Arising from Digitalization –Interim Report).
The same day ... Read More
May 8, 2018Leon Harris
25
Apr2018
As Israel celebrates 70 years of independence, it is good to note what makes the start-up nation innovative and successful. A recent OECD report attributes this success in large part to venture capital (VC) funds (A Portrait of Innovative Start-Ups Across Countries). On March 14, the Israeli Tax Authority issued updated guidance ... Read More
April 25, 2018Leon Harris
11
Apr2018
At Passover we celebrated our exodus from Egypt and the season of our freedom. In modern times, that means the start-up nation in the promised land is free to make money from exits – selling tech and other businesses to multinational groups that need to stay ahead at all costs. ... Read More
April 11, 2018Leon Harris