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 ...
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 ...
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) ...
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
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 ...
September 17, 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
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
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 ...
March 14, 2018Leon Harris