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Recommendations of the International Taxation Reform Committee

17 November 2021

Dear Clients, Colleagues and Friends,

We would like to update you that the Israel Tax Authority Committee for International Tax Reform, headed by CPA (Advocate ) Roland Am Shalem, has submitted  its recommendations to the Director of the Israel Tax Authority (the “Committee” and the “Committee Report” respectively).

The Committee Report was prepared by the Israel Tax Authority (the “ITA“) in consultation with the Israel Bar Association and the Institute of Certified Public Accountants in Israel. Representatives of our firm, Adv. Meir Linzen and Adv. Guy Katz, served as active members of the Committee on behalf of the Israel Bar Association.

The Committees Report recommends many significant changes with respect to various provisions relating to international taxation in the Income Tax Ordinance [New Version] 5721-1961 (the “Ordinance“). The declared purpose of the Committee Report is to deal with enforcement difficulties and lack of information, to close tax loopholes and to reduce the risk of money laundering.

Although the stated goal of the Committee Report is to improve  tax collection and expand reporting obligations, some of the Committee Report recommendations would also add certainty and clarity to the tax law, which will also benefit taxpayers.

If the recommendations are  adopted by the Israeli legislature, in whole or in part, they will have far-reaching consequences regarding tax liability, reporting obligations and other administrative obligations, both for individuals and companies.

Due to the fact that the tax authorities acted in cooperation with the professional associations in drafting the Committee Report, and consulted with other professional bodies and received their comments, it is expected that the recommendations included in the Committee Report will indeed eventually be enacted into law without substantial changes.

This Client Update briefly summarises the main recommendations included in the Committee Report. In the coming days and weeks, we will further update regarding the Committee Recommendations on the various issues in more detail.

 

1. Individual residency

An individual, who is considered a resident of Israel, is taxed on his or her worldwide income and is subject to broader reporting obligations, compared to an individual who is not a resident of Israel.

Under existing law, an individual will be considered a resident of Israel if that  person’s centre of life is in Israel. The centre of an individual’s life is determined based on all of the person’s familial, economic and social ties.

In addition, the Ordinance establishes a rebuttable presumption, according to which an individual is a resident of Israel if he or she has stayed in Israel for at least 183 days in a single tax year, or at least 30 days in a single tax year and at least 425 days in total in the tax year and in the two preceding tax years. On the other hand, the Ordinance stipulates that an individual who stayed in Israel for less than 183 days for two consecutive tax years, and whose centre of life is outside Israel in the two subsequent consecutive tax years, will be considered a foreign resident as of the first tax year.

The existing law results in many disputes between the ITA and taxpayers regarding the “centre of life”, and the level of certainty regarding an individual’s residency, both for the ITA and the taxpayers, is relatively low.

In order to increase the certainty on this matter, the Committee recommends adding to the Ordinance a number of irrefutable presumptions, based on the number of days spent in Israel only, which will be decisive in determining individual residency.

Where the conditions of the irrefutable presumption are not met, the taxpayer’s residency will be determined according to the “centre of life” test, including the rebuttable presumptions under existing law.

Below is a summary of the irrefutable presumptions:

 

Scenario
Remarks
Cases in which the individual will be considered a resident of Israel

 

An individual stayed for at least 183 days in each tax year for two consecutive tax years. Will be considered a resident as of the first tax year.
An individual stayed in Israel for at least 100 days a year, and also stayed in Israel for at least 450 days in the tax year and the two preceding tax years. This presumption shall not apply if the individual is a resident of a country that signed a tax treaty with Israel (“Tax Treaty Country”), in which he or she stayed for at least 183 days during each of the tax years under examination.
The individual stayed in Israel for at least 100 days a year, and his / her spouse is a resident of Israel.
Cases in which the individual will be considered a foreign resident
An individual stayed in Israel for less than 30 days a year for four consecutive tax years. 1. Applicable as of the first tax year.

2. Applies if the individual has not stayed in Israel for at least 15 days during the first month of the first tax year or the last month of the last tax year.

An individual stayed in Israel for less than 30 days a year for three consecutive tax years. 1. Applicable as of the second tax year.

2. Applies if the individual has not stayed in Israel for at least 15 days during the first month of the first tax year or the last month of the last tax year.

An individual and his / her spouse have each stayed in Israel for less than 60 days a year for four consecutive tax years. 1. Applicable as of the first tax year.

2. Applies if they have not stayed in Israel for at least 30 days during the first two months of the first tax year or the last two months of the last tax year.

An individual and his / her spouse have each stayed in Israel for less than 60 days a year for three consecutive tax years. 1. Applicable as of the second tax year.

2. Applies if they have not stayed in Israel for at least 30 days during the first two months of the first tax year or the last two months of the last tax year.

An individual and his / her spouse have each stayed in Israel for less than 100 days a year for four consecutive tax years and stayed at least 183 days in a Tax Treaty Country and produced a residency certificate from such Tax Treaty Country. 1. Applicable as of the first tax year.

2. Applies if they have not stayed in Israel for at least 50 days during the first 100 days of the first tax year or during the last 100 days of the last tax year.

An individual and his / her spouse have stayed in Israel for less than 100 days a year for three consecutive tax years and they stayed at least 183 days in a Tax Treaty Country and produced a residency certificate from such Tax Treaty Country. 1. Applicable as of the second tax year.

2. Applies if they have not stayed in Israel for at least 50 days during the first 100 days of the first tax year or during the last 100 days of the last tax year.

 

 

2. Foreign tax credit

In order to avoid double taxation of income that is also taxable in another country, Israeli law currently stipulates that foreign taxes that were paid in a foreign country by an Israeli resident can be credited against Israeli tax liability, subject to certain restrictions and conditions.

The most significant limitation is the “basket system”, according to which foreign taxes will be credited only against tax liability for income from the same source (“basket”), regardless of the country in which the foreign taxes were paid. Foreign taxes that cannot be credited (“excess credit”) can be offset in the five subsequent tax years only against taxes on income from the same basket.

The current basket system is quite complicated and raises difficulties, which may result in a loss of the credits for taxes paid in a foreign country.

Below are the main recommendations with respect to foreign tax credits:

a. Reliefs in the basket system, which will include only five baskets:

  • An active basket, which will include income from a business and personal exertion;
  • A passive basket, which will include passive income, such as dividend income, interest, royalties, rent, etc.;
  • Capital gains basket, which will include capital gains;
  • A CFC basket, which will include notional income in respect of a Controlled Foreign Company;
  • A FPC basket, which will include notional income in respect of a Foreign Professional Company.

 

b. Limiting carry forward of the excess credit to subsequent years.

According to the Committee Report, taxpayers will be entitled to carry forward excess credits to subsequent years only if such excess credit (1) was derived from offsetting income against losses in Israel, or (2) was derived from timing differences in income reporting in Israel and the source country.

c. A foreign tax credit will be allowed only if it is not claimed in another jurisdiction.

Foreign tax credit claimed by U.S. citizens and foreign taxes claimed as indirect credits will be excluded from this rule.

d. Limitations on the countries for which foreign taxes can be credited.

Taxpayers will not be allowed to claim a foreign tax credit with respect to taxes paid to countries to do not exchange information with Israel and that will allow Israel to confirm that foreign taxes were actually paid.

Accordingly, taxes paid to enemy countries or to countries that will be included in a list to be determined by the ITA (similar to the “black” and “gray” lists of the European Union), will not be eligible for a tax credit at all.

For other countries with which there is no exchange of information, in order to qualify for a credit with respect to taxes paid, it will be necessary to apply for prior approval from the ITA , before submitting the tax return.

e. Indirect Credit.

Under Israeli law, indirect credit can only be granted with respect to subsidiaries and second-tier subsidiaries (i.e. two layers of holding) if the ownership percentage in the subsidiary is at least 25%, and the ownership percentage of the subsidiary in the second tier subsidiary is at least 50%.

The Committee Report recommends increasing the scope of eligibility for indirect credit to third tier subsidiaries (three layers below the Israeli company) and to fourth tier subsidiaries (four layers below the Israeli company), subject to meeting certain conditions regarding the ownership percentage in these companies (In general, the direct ownership percentage in third and fourth tier subsidiaries should be at least 50% and the effective ownership percentage of the Israeli company in such subsidiaries should be at least 12.5%).

On the other hand, it was recommended that an indirect credit be granted only if the company met the conditions regarding the ownership percentage for a period of at least 12 months preceding the date of distribution of the dividend.

 

3. Exit tax.

Under existing law, a person (individual or company) who ceases to be an Israeli resident is liable to exit tax, as if it had sold all its assets on the date in which it ceased being an Israeli resident. As a default, the taxpayer is viewed as if it had elected to defer the date of payment of exit tax until the date of actual sale of the assets.

At the time of the actual sale, the exit tax will apply only in respect of the proportionate share of the gain on the sale that is allocable to Israel, calculated as the number of days in which the property was held until the termination of Israeli residence, divided by the total number of days in which the property was held until sale (the “Linear Method”).

The Committee Report recommends extensive changes to the provisions relating to exit tax, which are primarily intended to ensure the ability of the ITA to effectively collect the tax.

Similar to the current law, taxpayers who have terminated residency will be allowed to elect whether to pay the exit tax immediately or to postpone the tax payment to a later date. However, the Committee recommends that both routes will have more extensive reporting obligations, and that the Assessing Officer will be entitled to demand certain guarantees to secure future tax payment.

Accordingly, two different regimes are suggested, depending on the value of the assets subject to exit tax, as follows –

a.When the value of the assets subject to exit tax does not exceed 3 million NIS: The provisions of the existing law will apply (i.e., tax will be due immediately when the taxpayer left Israel or alternatively the tax event can be deferred until actual sale, at which time the gain will be calculated according to the Linear Method), but a reporting obligation will be added, according to which a taxpayer leaving the State of Israel will be required to report all of its assets within 90 days. The aforesaid reporting obligation will apply annually until the date of full payment of exit tax.

b. When the value of the assets subject to exit tax exceeds 3 million NIS: In this case, the provisions of the new law will apply, and the assets will be divided into three groups –

  • Group A – Tradable Securities. Tradable securities will be deemed sold on the day of termination of residency in exchange for their market value (i.e., there will be no possibility of tax deferral ).

 

  • Group B – Real Estate Located Outside of Israel. Similar to the existing law, real estate property located outside of Israel will be deemed sold on the day in which the Israeli residency was terminated, but it will be possible to defer the payment of the exit tax until the date of actual sale (using a linear calculation). For this group of assets, as a condition for tax deferral, the taxpayer will be required to deposit a guarantee or to pledge the assets with an Israeli trustee, if the effective tax liability for the sale of the real estate assets (after taking into account foreign taxes) exceeds NIS 1.5 million. If the effective tax is lower than such amount, the taxpayer will be charged with reporting obligations only (without providing collateral).

 

  • Group C – Other Assets. Similar to the existing law, assets that are not included in Group A and Group B above, will be deemed sold on the day in which the Israeli residency was terminated, but it will be possible to defer the payment of the exit tax until the date of actual sale (using a linear calculation). Reporting obligations will be imposed on the taxpayer, and if it elects to defer tax liability, a guarantee or pledge will need to be deposited with an Israeli trustee as a condition of deferring the tax liability.

 

With respect to each of the aforesaid cases, the taxpayer will also be charged with reporting obligations, according to which a taxpayer will need to report its assets within 90 days from the date in which its Israeli residency was terminated. The aforesaid reporting obligation will continue annually until the date in which the full exit tax has been  paid.

The Committee also included a number of  very significant additional recommendations related to the exit tax as follows –

a. The tax route elected by the taxpayer will apply to all the properties (it will not be possible to elect different routes with respect to different properties).

b. Stock-based compensation to employees will be excluded from the exit tax and the Israeli taxable income will be calculated in accordance with the Vesting method.

c. The Committee recommends certain changes regarding the applicability of the exit tax to corporations. According to the Committee Recommendations, corporations will also be subject to exit tax in respect of profits accrued up to the date of change of residency. These gains will be taxed immediately as if they had been distributed as a dividend, except for gains from a notional sale at the date of change in residency to which the tax deferral route could be applied and would be considered as distributed as a dividend at the time of realisation.

d. The Committee recommends that the exit tax will apply immediately in respect of the transfer of assets or business activity by an Israeli company from the main office to a permanent establishment abroad and by a foreign company, from a permanent establishment in Israel to the main office abroad or to another permanent establishment.

e. The Committee recommends that in the deferral route, dividends distributed by a foreign resident company (until the exit tax is paid for the actual sale of the shares in the foreign resident company) will also be subject to the exit tax. Such dividends will be considered as a partial sale of the company shares. This is an amendment to a significant lacuna in the exit tax regime that exists currently in Israel.

f. As an anti-avoidance measure, the provisions of the linear calculation and the liability for exit tax will not apply to a taxpayer who has returned to Israel within 4 years of departure. This provision will not apply if the taxpayer became a resident of a country with which Israel has a double tax treaty during the entire period.

g. The Committee recommends that the exemption provisions under Section 97(b3) of the Ordinance shall not apply to assets subject to exit tax. This means that Israeli residents who own shares in Israeli companies, and leave the State of Israel, will not be able to claim a linear calculation and instead will be charged with full tax upon the sale of the company shares. Such taxpayers may claim a linear calculation only where a sale is exempt under an applicable double tax treaty.

h. Relief for taxpayers who has left and returned to Israel. The Committee recommends that the exit tax provisions shall not apply to taxpayers who returned to Israel within 5 years of departure, provided that the assets that they owned were not sold during this period.

 

4. Controlled Foreign Company (CFC).

The Ordinance currently stipulates that a foreign resident company in which more than 50% of its shares are held, directly or indirectly, by Israeli residents (or 40% of its shares are held by Israeli residents, but over 50% of its shares are held by Israeli residents together with their non-resident relatives), and most of its profits or income are  derived from passive income, will be considered a CFC.

The controlling shareholder of a CFC (generally, referring to an Israeli resident shareholder who holds at least 10% of the shares of the CFC) will recognise income from a deemed dividend each year in the amount of the profits resulting from the company’s passive income which have not yet been distributed as a dividend.

The Committee recommends to expand the CFC provisions, as follows:

a. First, the Committee recommends expanding the term “passive income” by including additional types of income:

  • Insurance premiums and royalties paid by a related party, even if otherwise classified as business income, except where the royalty income is recorded by a company that has the capacity to bear the risks related to the IP and in cases where the IP was acquired by an unrelated party or the IP was developed by the company;

 

  • Interest income paid by a related party, even if otherwise classified as business income, if one of the following applies: (1) as a result of the payment of interest, the paying party will no longer be considered a CFC, (2) the paying party is a resident of Israel (including a permanent establishment of a non-Israeli resident), or (3) the Israeli company has directly or indirectly issued an interest-free capital note to a related party;

 

  • Benefits arising from financial assets (such as loan transactions);

 

  • Business activity used to divert profits – in cases where business income is recorded from royalties in a company that is unable to bear the risks involved.

 

  • Capital gain from the sale of intangible assets, even if otherwise classified as business income, provided that the asset sold is held for more than one year. This would be a rebuttable presumption. In addition, the Director of the ITA will have the authority to disregard such profit where the intangible asset is sold to an Israeli company.

 

b. It is recommended to compile a “blacklist” of countries (based on the “black” list and the “gray” list published by the European Union, plus additional countries that have not signed an agreement with Israel for the exchange of information). For companies incorporated in countries included in the blacklist, the control rate for CFCs will be only 30% (instead of 50%), and the CFC mechanism will apply to all passive income, regardless of their share of total income or profits.

c. It is recommended to lower the passive income test threshold to only a third of the foreign company’s total income / profits instead of 50% today.

d. It is recommended that a New Immigrant or a Senior Returning Resident will be counted as an Israeli resident for the purposes of the definition of a CFC (although the deemed dividend to these residents will still be exempt from tax). This provision will only apply to properties acquired after the date of immigration to Israel (“Aliyah”).

e. Changes were suggested to the manner in which the income, passive income and profits that have not yet been distributed by CFC are calculated; the Director of the ITA will be given the authority to exempt spin-offs from tax.

 

5. Reliefs for New Immigrants and Returning Residents.

Israeli law provides a wide range of benefits to New Immigrants, Senior Returning Residents and Returning Residents. A person who becomes a resident of Israel for the first time (New Immigrant) or takes up residence in Israel after a period of at least 10 consecutive years in which he or she was a foreign resident (Senior Returning Resident), is exempt from tax and reporting obligations with respect to foreign source income and assets situated outside of Israel for a period of 10 years from the date in which he or she became an Israeli resident.

A person who takes up Israeli residence after a period of at least 6 consecutive years in which he or she was a foreign resident (Returning Resident) is exempt from tax on foreign source passive income (dividend, interest, royalties, pension and rent) for a period of 5 years and is also exempt from foreign source capital gains tax for 10 years, provided that the assets generating the income or profit were acquired during the period in which he or she was a foreign resident (but returning residents are not exempt from reporting).

The Committee recommends that the New Immigrants’ and Senior Returning Residents’ exemption from reporting on income and assets outside Israel will be revoked. The repeal of the exemption will apply only to New Immigrants and Senior Returning Residents who arrived in Israel after the date in which the new law will enter into force. It should be noted that the Bar Association objected to this recommendation.

At this stage, and under pressure from the professional associations, the Committee did not recommend a complete repeal of, or substantial change to the benefits regime to New Immigrants and Returning Residents.

 

6. LLC Companies.

One of the most severe tax distortions in the field of international taxation is related to the difference in the treatment of LLCs in U.S. law compared to Israeli law.

While in the U.S. LLCs are considered “transparent” by default, so that their income and losses are attributed to the LLC members, in Israel the tax system treats these companies as separate legal entities that are liable to corporate tax. The ITA has previously, via circulars, provided  relief in relation to LLC companies and has determined that, with respect to foreign tax credit only, LLC income can be attributed to its members.

Despite the relief, over the years the ITA has refused to recognise the LLC as a completely transparent entity, so losses incurred by one company cannot offset profits generated by another company. This position has created many distortions and exposed taxpayers to double taxation on U.S. investments.

The Committee recommends a partial reform in this area by updating income tax circulars so that U.S. source losses of an LLC only could offset income from U.S. sources or assets of the LLC’s member only (including taxable income from LLCs, partnerships and other S corporation companies).

 

7. Reporting Obligations.

The Committee Report recommends a considerable expansion of taxpayers’ reporting obligations. The following is a brief list of the additional obligations that should be applied, according to the Committee recommendations:

a. Extended reporting obligations regarding holdings in foreign companies. Special controlling shareholders (in general, any person who holds 50% or more of the rights in the company or who holds only 25% or more of the rights and other Israeli residents together hold over 50% of the rights in the foreign company), will be required to file the financial statements of the foreign companies held directly by him. In addition, the Assessing Officer will be given the authority to require financial statements of companies held indirectly.

 b. Expansion of the required reporting regarding holdings in foreign companies under Form 150. For all controlling shareholders (any person who holds at least 10% of the rights in a foreign company), the reporting provisions in Form 150 have been significantly expanded and this form is expected to include more details, such as total turnover, payments to related parties and etc.

c. Decreasing the reporting threshold with respect to foreign assets. The Committee recommends reducing the minimal financial threshold for reporting holding of property outside of Israel, to an amount of NIS 1,000,000 (instead of approximately NIS 1,800,000 today). It is also been determined that “distributed means of payment” (cryptocurrencies) will also be considered an asset for this purpose.

d. Obligation to file annual returns for certain foreign corporations, plus the obligation to explain why control and management are exercised outside of Israel. It is recommended that foreign companies at least 50% of the shares in which are held by Israeli residents, and which are subject to tax at a rate of less than 15%, will under certain conditions be required to open a tax file in Israel, and to explain why the company should not be considered a resident of Israel.

 e. Extension of reporting obligations to those leaving Israel. Any person leaving Israel will be required to report to the tax authorities within 90 days of the date of departure and to report all of his or her assets that are subject to exit tax. The reporting obligation will continue annually until the full exit tax is paid (in the event that a deferral is granted). In addition, a resident of Israel who has been outside of Israel for 183 days, and claims that he has not yet severed his residency, will be required to report this to the tax authorities.

f. Reporting gifts. Individual residents of Israel will be required to report any receipt from abroad / gift at a value of over NIS 500,000.

 In addition, the Committee Report includes extensive recommendations regarding the adjustment of the reporting obligations in Israel to the international standard set out in EU’s DAC 6. Accordingly, the Committee recommends amending the regulations on reportable tax planning so that they also include certain “international arrangements”, which include “hallmarks” of alleged tax planning. At this stage, the tax planning arrangements that will be included in the regulations have not yet been fully specified. These  reporting obligations will apply to the taxpayers only and will not apply to financial intermediaries or other service providers (attorneys and accountants) as is customary in DAC 6.

 

8. Taxation of Options to Employees on Relocation.

Tax Ruling 989/18 provides that stock options that were received by a foreign resident and were exercised after he or she returned to Israel, will be subject to tax in Israel (as the state of residency), also with respect to the portion of the vesting period in which the holder was a foreign resident (the provision is only relevant for “Returning Residents”). Following the Bar Association’s request, and in order to encourage people to return to Israel, the Committee recommends a temporary provision that will state that income generated during the period in which a taxpayer was a foreign resident will be tax-exempt, even if received after returning to Israel.

 

9. Entry and Exit of Assets to the Israeli Tax System.

The Committee considered how to tax assets that enter and exit the Israeli tax system. The Committee members have not reached a decision on this issue and it was decided to recommend one of the following two alternatives –

  • Imposing an exit tax even when an Israeli resident passed away and his or her heirs are foreign residents. Under this alternative, the provisions of the step-up mechanism for assets introduced into the Israeli tax system will remain. The step-up mechanism allows Israeli residents to enjoy a new cost base for properties they have inherited or received as a gift from foreign residents.

 

  • Not to impost exit tax on assets that are bequeathed to a foreign resident but on the other hand to cancel the step-up mechanism on assets that are received from foreign residents as a gift of by way of inheritance.

 

10. Hybrid Mismatches.

The Committee recommends adopting BEPS Action 2. In principle, this is a denial of a deduction or imputation of income in cases where taxpayers make hybrid arrangements for the purpose of reducing the tax liability in Israel. The provisions of Action 2 are almost fully adopted and will apply to any transfer specified in the recommendations that in the aggregate is in excess of NIS 500,000 per year.

These are extremely complicated and complex instructions, which we will detail in a separate circular. As an example, the recommendations will deny an expense deduction in Israel when as a result of a hybrid device no income was included in the payee’s country.

When the recipient is an Israeli resident and the payor’s country has not implemented this recommendation, the resident of Israel should be attributed income in Israel at the amount of expenditure allowed in the foreign country.

For example, where an Israeli resident company received a loan from a foreign company and the foreign company classified this loan as capital, then interest expenses were claimed in Israel while the foreign company classified the payment as an exempt dividend. In this case, the recommendations state that the State of Israel will deny the deduction of expenditure by the Israeli company.

 

11. Miscellaneous.

 a. Taxation of foreign journalists and foreign athletes. The Committee also recommends far-reaching changes to the taxation of foreign journalists and athletes. In principle, it is proposed to stipulate that the benefit period for foreign journalists will be one-time and will apply from the date of their arrival in Israel (and not from the date of commencement of activity).

b. Liquidation / sale of an Israeli company with accumulated profits arising from real estate in Israel. The Committee recommends correcting a distortion that exists today in the provisions of the exemption for foreign residents, according to which in order that an exemption does not apply to a company that has most of its holdings in real estate in Israel, it is required that most of the value of the company’s assets be from real estate on the day of purchase and also in the two years preceding the day of sale. The committee recommends canceling the terms of the day of purchase and extending the two-year period from the date of sale to three years.

c. Amendment of the source rules regarding the payment of interest, royalties and annuities. The Committee recommends that wherever interest, royalties or annuities are paid to a foreign resident, and the payment of the taxable income in Israel is reduced, the income will be regarded as income from an Israeli source, even where the foreign resident does not have a permanent establishment in Israel.

 

12. Issues discussed in the Committee Report and not formulated as recommendations.

The Committee discussed a number of additional issues that ultimately were not formulated into recommendations. Among other things, the Committee discussed the imposition of a branch tax, but left  the issue imposition for further review and did not recommend  its imposition. The Committee also recommended that the discussion on trust taxation and the discussion on the establishment of “thin capitalisation” rules (Action 4 of the BEPS) be submitted for discussion to designated committees.

The many recommendations in the Committee Report are expected, if enacted into law, to fundamentally change the current international tax regime in Israel. These changes require a re-examination of existing tax structures and advice provided in the past.

We are available for our clients who are interested in examining the impact of these recommendations .

An early examination of the potential effects of the recommendations of the Committee Report may prevent “tax accidents” down the road.

In the coming days and weeks, we will expand further on the various recommendations of the Committee and will remain updated on the progress of the legislative procedures in order to ensure that our clients and colleagues have all the information needed to prepare for the expected reform in this field.

 

Sincerely,

Tax Department

Herzog Fox & Neeman

 

Key Contacts:

Meir Linzen | Chairman
Chairman of the firm and head of tax department
linzen@herzoglaw.co.il
Guy Katz | Partner
Tax Department
katzg@herzoglaw.co.il
Yuval Navot | Partner
Tax Department
navoty@herzoglaw.co.il
Ofer Granot | Partner
Tax Department
granoto@herzoglaw.co.il
Shachar Porat | Partner
Tax Department
porats@herzoglaw.co.il
Amir Cooper | Partner
Tax Department
cooperam@herzoglaw.co.il