Category: International Tax Planning


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


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


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


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


The Israeli Tax Authority has just published a controversial tax ruling that imposes partial tax on a foreign investment fund. Background: Section 108 of the Israeli Income Tax Ordinance (ITO) empoweres the ITA to collect tax from an Israeli resident who represents a foreign resident. And the Israeli Tax Authority (ITA) claims ... Read More
March 14, 2018Leon Harris


The Israeli Tax Authority (ITA) has just published detailed instructions regarding the 2018 voluntary disclosure program (VDP or amnesty) which expand on the ITA’s initial announcement of December 12, 2017 (Operating Instructions 5/2018 of February 13, 2018).  The new instructions will create extra work for amnesty applicants and their advisors. Background: The 2018 ... Read More
February 21, 2018Leon Harris


The Israeli Tax Authority (ITA) announced a new voluntary disclosure program (VDP or amnesty) for applications filed by taxpayers between December 12, 2017 and the end of 2019. The new program replaces an earlier program that stopped accepting applications at the end of 2016. The ITA reports that 7,549 applications were ... Read More
December 19, 2017Leon Harris


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


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


Are Bitcoins and Other Virtual Currencies Tax-Exempt? In 1964, the Dave Clark Five pop group raised room temperatures with their foot stomping hit “Bits and Pieces”. In 2017, the rise in bitcoin prices is again raising room temperatures. To add to the euphoria, some think there is a big Israeli tax loophole. With ... Read More
October 25, 2017Leon Harris