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

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

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

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

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

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

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

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

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