This year Israel introduced new rules for taxing personal “wallet companies” which pay company tax at a rate of 24% in 2017, but no more if profits are left in the company’s bank account. These rules tax deemed dividends, loans to major shareholders and personal services provided via such a ... Read More
Category: Israeli Exempt Companies
13
Dec2017
OECD Deals Get Out of Jail Card
On November 8, the OECD issued important guidance on how governments can catch tax evaders and, significantly, what rights taxpayers have. (“Fighting Tax Crime: The Ten Global Principles”).
OECD guidance is back-door law in OECD member countries such as Israel. Article 6 of the OECD Convention, ... Read More
December 13, 2017Leon Harris
30
Nov2017
בשנת 2018 ישראל עומדת לתקן את כל 56 אמנות המס שלה בבת אחת וזאת עקב חתימתה בתאריך 7.6.2017 על אמנה רב צדדית של ארגון ה - OECD על מנת ליישם הוראות הקשורות ל- Base Erosion and Profit Shifting) BEPS).
BEPS הינה תכנית מקיפה של ארגון ה-OECD כנגד הזזת רווחים למקומות אופשור (offshore), ... Read More
November 30, 2017Leon Harris
26
Nov2017
Israelis in hitech and other industries are often relocated to work abroad. At what time do they become foreign residents? For many years this was a mystery. The Israeli tax law says that dropping Israeli fiscal residency takes at least four tax years – two years in Israel under 183 ... Read More
November 26, 2017Leon Harris
13
Nov2017
Israel has seen a wave of exit deals. Exits can be paid for with cash or shares of the acquirer, especially if the acquirer’s shares are publicly traded on a stock exchange – that is as good as cash isn’t it? Not if there is immediate tax to pay and ... Read More
November 13, 2017Leon Harris
24
Oct2017
Information Exchange Gathers Pace
The first wave of automatic Common Reporting Standard (CRS) information exchanges has just begun between 49 countries. This is according to an OECD announcement on September 15. The 49 countries include Argentina, Barbados, Belgium, Bermuda, BVI, Cayman Islands, Cyprus, Czech Republic, Denmark, Estonia, France, Germany, Gibraltar, Greece, Guernsey, ... Read More
October 24, 2017Leon Harris
24
Oct2017
Israel amends all 56 tax treaties
In 2018, Israel’s 56 tax treaties may be amended in one go after signing on June 7, 2017 the OECD multilateral instrument (MLI) to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS). BEPS is the OECD program aimed at preventing offshore ... Read More
October 24, 2017Leon Harris
04
Oct2017
President Trump and the Republican party issued a tax reform “framework” plan on September 27. It’s only 9 pages long so we don’t yet have full details and it has yet to be enacted. Given that, what’s in store for US businesses, US Olim, and everyone else?
Business Taxation
The framework proposes ... Read More
October 4, 2017Leon Harris
27
Sep2017
In recent months we have witnessed several exit deals where Israeli hitech companies have been sold for a pretty penny.
But suppose some of the consideration payable to the founders and key employees is held back and subject to staying on for a period as an employee in the post-acquisition group?
Is ... Read More
September 27, 2017Leon Harris
27
Sep2017
The Israeli Tax Authority published final instructions regarding Reverse Vesting shares on June 5 (Circular 5.2017. This will be of interest to many people in the Start-Up Nation.
Until now, founders and key personnel holding 10% or more of a company seemed to miss out on the opportunity to pay only 25% tax ... Read More
September 27, 2017Leon Harris