The OECD has been caught dawdling on the information superhighway, the Internet. This is surprising as the OECD dazzled us in 2015 with souped up worldwide tax initiatives for nearly everyone. Corporations got hit by BEPS - base erosion and profit shifting. Individuals got hit by CRS – Common Reporting Standard. ...
March 19, 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
The Israeli Tax Authority has just published a controversial tax ruling that imposes partial tax on a foreign investment fund with an Israeli presence. Background: Section 108 of the Israeli Income Tax Ordinance (ITO) empowers the ITA to collect tax from an Israeli resident who represents a foreign resident. And the Israeli ...
March 12, 2018Leon Harris
החלטת רשות המסים פוגעת בקרנות השקעה זרות בישראל ליאון הריס רשות המסים בישראל פרסמה זה עתה החלטה מקדמית, המטילה מס חלקי על קרנות השקעה זרות מסויימות. רקע כללי: סעיף 108 לפקודת מס הכנסה בישראל מאפשר לרשות המסים לגבות מס מתושב ישראל המייצג תושב חוץ. רשות המסים טוענת כי רווחים ממכירת מניות וניירות ערך הינם ...
March 12, 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 ...
February 21, 2018Leon Harris
The Start-Up nation thrives on cash. Where can an Israeli business find financial assistance? Try government sources including the Israel Innovation Authority - formerly the Office of the Chief Scientist and Matimop. Here is a brief overview. Competitive Research and Development: This program offers Israel’s primary financial incentives for R&D activities from ...
January 25, 2018Leon Harris
The Israeli Tax Authority (ITA) has just relaxed its procedure for enabling Israelis in less central locations in Israel to get tax breaks for doing so. The ITA announced on November 7, 2017, that it will now allow “privileged” municipal authorities to send their residents self-initiated but targeted confirmations of residency ...
January 3, 2018Leon Harris
This year Israel introduced new rules for taxing personal “wallet companies” which pay company tax at a rate of 24% in 2017, but no more if profits are left in the company’s bank account. These rules tax deemed dividends, loans to major shareholders and personal services provided via such a ...
January 2, 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 ...
December 19, 2017Leon Harris
OECD Deals Get Out of Jail Card On November 8, the OECD issued important guidance on how governments can catch tax evaders and, significantly, what rights taxpayers have. (“Fighting Tax Crime: The Ten Global Principles”). OECD guidance is back-door law in OECD member countries such as Israel. Article 6 of the OECD Convention, ...
December 13, 2017Leon Harris