The Israeli Supreme Court has just shot down the use of a company incorporated in Ramallah (Shai Tzmarot (Oranit) Vs VAT Director Petach Tikva, Civil Appeal 1609/16, handed down November 1, 2018). This was done using the old UK tax concept of central management and control, but with a Hebrew ... Read More
Category: International Tax Planning
20
Nov2018
The Bank of Israel Bank Supervisory Department published draft new instructions to Israeli banks regarding checks required to ascertain whether money was properly taxed. In 2016 certain tax offenses were made “predicate offenses” under Israel’s anti money laundering rules, which Israeli banks administer. In other words Israeli banks were turned ... Read More
November 20, 2018Leon Harris
19
Nov2018
Those that look ahead, get ahead. Business profits and taxes need to be monitored regularly, especially towards the tax year-end of December 31. Below is a starter list of planning tips to check out
On The Business Side:
First, a business plan. What are your goals and are you achieving them? What is your competitive ... Read More
November 19, 2018Leon Harris
15
Nov2018
Pension contributions are important in providing for our retirement years. Below is a brief overview of Israeli tax law rules for 2018.
Types of Members
The tax law distinguishes between “Privileged” and “Non-privileged” members of a provident fund, who may also be employed or self-employed.
A privileged member is one who contributes at ... Read More
November 15, 2018Leon Harris
22
Oct2018
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 ... Read More
October 22, 2018Leon Harris
22
Oct2018
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 ... Read More
October 22, 2018Leon Harris
22
Oct2018
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) ... Read More
October 22, 2018Leon Harris
17
Sep2018
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 ... Read More
September 17, 2018Leon Harris
17
Sep2018
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 ... Read More
September 17, 2018Leon Harris
11
Jul2018
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