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 ...
October 22, 2018Leon Harris
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 ...
September 17, 2018Leon Harris
Entrepreneurs across the start-up nation dream day and night about their multi-million dollar exit. Serial exiters know it isn’t so easy. Exit deals take on a life of their own, especially if you don’t plan ahead and build in some shock absorbers too. One of the reasons is that even ...
September 17, 2018Leon Harris
In the start-up nation, many hitech employees enjoy share (stock) plans and share option plans. In May 2018 the Israeli Tax Authority (ITA) published a new batch of tax rulings which clarify Section 102 of the Income Tax Ordinance (ITO). What did the ITA say? Section 102 Section 102 of the ITO allows ...
July 26, 2018Leon Harris
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 ...
July 11, 2018Leon Harris
The Israeli Supreme Court has just issued a judgment of interest to the Israeli hitech and industrial sectors and their employees (Kontera Technologies Ltd v Tel-Aviv 3 Assessing Office 943/16, Finisar Israel Ltd v Rehovot Assessing Officer 1728/16). Transfer Pricing in Israel: The Supreme Court handed down a combined judgment relating to ...
June 13, 2018Leon Harris
New restrictions will limit the use of cash and blank checks (cheques) commencing the beginning of 2019 pursuant to a law just passed by the Knesset (Law Limiting the Use of Cash, 2018, Book of Laws 2710). The new law distinguishes between businesses, consumers (referred to as non-businesses) and tourists. A business ...
May 23, 2018Leon Harris
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 ...
May 8, 2018Leon Harris
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 ...
April 25, 2018Leon Harris
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. ...
April 11, 2018Leon Harris