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) ...
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 ...
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 ...
The Israeli Tax Authority recently published a series of reminders that businesses in Israel must keep proper account books. Approved Israeli software or printed books must be used – not Excel, Word, QuickBooks or Sage. Otherwise, the Israeli Tax Authority (ITA) not only levies fines, it can also estimate taxable income, ...
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 ...
When Paul Simon sang the hit Slip Slidin’ away, he had in mind a girl called Delores. When the OECD recently published a report on intangible assets sliding away, they had in mind Dollars and Euros (Guidance for Tax Administrations of the Approach to Hard-to-Value Intangibles, June 2018). The report clarifies certain ...
August 20, 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