Tax
Herzog Fox & Neeman has the strongest Tax practice of any law firm in Israel. The Tax practice is preeminent due to the scope of its work, its expertise in international tax planning, and its influence on Israel’s tax regime.
Herzog Fox & Neeman’s tax lawyers have long been involved in structuring major international transactions, as well as obtaining landmark tax rulings that have shaped Israel’s Hi-Tech and venture capital industry.
The tax practice is comprised of six specialized areas:
- Corporate Tax - Tax Aspects of M&A and Capital Markets Transactions and Current Corporate Tax Advice - The Tax department has been involved in the tax aspects of most of the transactions handled by the firm, as well as in the tax planning for many of the multinational corporations operating in Israel. The department’s lawyers create and implement sophisticated structures to optimize the global tax efficiency of the firm’s clients
- Private Clients, Trusts, and Estates – The Private Clients, Trusts, and Estates group is located within the Tax department and provides unparalleled service to high net worth individuals. The group regularly handles complex cross-border tax and estate planning to optimize families’ goals regarding global tax efficiency.
- Investment Funds / Private Equity - Since the infancy of the investment funds industry in Israel, Herzog Fox & Neeman has led the way in the growth of the venture capital, private equity fund, and hedge fund industries in Israel. The Investment Funds / Private Equity group represents numerous domestic and international investment funds with a variety of fields of activities
- International Tax Planning – The International Tax Planning group helps to coordinate and direct clients’ worldwide tax affairs - including strategies to minimize exposure to foreign corporate taxation, permanent establishment exposure, withholding taxes, European VAT and similar taxes and duties, and many exposures unique to particular jurisdictions.
- Transfer Pricing – Our transfer pricing department offers Israel’s most comprehensive guidance on international transfer pricing, with a full range of services, focusing on the legal, economic, and business-related aspects of the client's tax structure and supply chain. Our team prepares the required transfer pricing studies, in accordance with Israeli and foreign regulations (including the newly adopted OECD BEPS regulations), intercompany agreements, transfer pricing policies, APAs, transfer pricing valuations, and the BEPS readiness process.
- Employee Tax Benefits - The Employee Tax Benefits group is one of the few specialized groups in Israel and is the market leader. The group provides advice to public and private start-up companies, newly formed companies, multinationals, and subsidiaries on all aspects of employee equity benefits plans and employment agreements.
Tax News & Insights
Four tax rulings previously required with respect to equity incentive plans are no longer needed! We are pleased to update
Equity Plan Tax Rulings – Important Update
We are pleased to bring to your attention a number of updates in the fields of VAT and customs, effective
Overview of VAT and Customs Updates Effective in 2026
The OECD published on 19 November, 2025 an update to the articles and Commentaries of the Model Tax Convention on
OECD Releases Update to the Model Tax Convention – New General Approach on Employees Working from Home and the Israeli Perspective
The Ministry of Finance and the Israeli Tax Authority (ITA) announced, in a joint press conference on November 2nd 2025,
Multi-Stage Reform in the Taxation of High-Tech Companies
On November 2, 2025, the Israel Tax Authority (“ITA”) published a circular regarding the transfer pricing framework for Israeli R&D
Income Attribution for R&D Centers and Post‑Acquisition IP Sales
Introduction On October 28, 2025, the Tel Aviv District Court (Honorable Judge Yardena Sarusi) published its judgment in the tax
Taxpayer Wins in Landmark Transfer Pricing Case – Implications for M&A and Post-Transaction Sale of IP
The Israeli Ministry of Finance published on October 5, 2025, a draft bill to implement the principles of the OECD’s
New draft bill to implement Pillar Two rules in Israel
You are invited to join a unique webinar hosted by HERZOG in collaboration with Sullivan & Worcester, focusing on the
Customs and Transfer Pricing: How President Trump’s Tariff Policy Will Affect Israeli Multinationals
On August 25, 2025, the Israeli Tax Authority published a new “Voluntary Disclosure Procedure” effective until August 31, 2026 (hereinafter:
New Voluntary Disclosure Procedure in Israel
Herzog’s Private Clients, Trusts and Estates Department, ranked Band 1 by Chambers, authored the Israel overview for the latest HNW
Herzog’s Private Clients, Trusts and Estates Department, ranked Band 1 by Chambers, authored the Israel overview for the latest HNW 2025 directory.
On August 7, 2025, the Jerusalem District Court (Hon. Judge Avigdor Dorot) issued a judgment on an appeal filed by
New VAT Judgment: Bank’s Insurance Agency Can be Classified as a “Financial Institution”
Meir Linzen
Chairman
Corporate Tax, Employee Tax Benefits, Gaming, Indirect Taxes, Customs & International Trade, International Tax Planning, Internet & E-commerce, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax, Tax Controversy – Disputes & Litigation, Transfer Pricing, Value Added Tax (VAT)
Eyal Bar-Zvi
Partner
Commercial, Hi Tech, International Tax Planning, Mergers & Acquisitions, Tax, Transfer Pricing
Daniel Lipman Lowbeer
Partner
Corporate Tax, International Tax Planning, Internet & E-commerce, Mergers & Acquisitions, Tax
Efrat Kesler Kadmon
Partner
Employee Incentive Schemes, Employee Tax Benefits, Labour & Employment, Tax
Eitan Ella
Partner
Corporate Tax, Employee Tax Benefits, International Tax Planning, Private Clients, Trusts & Estates, Tax
Itamar Gur
Partner
Corporate Tax, International Tax Planning, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax
Mordechai (Moti) Fogel
Partner
Indirect Taxes, Customs & International Trade, Tax, Value Added Tax (VAT)
Omer Yaniv
Of Counsel
Corporate Tax, International Tax Planning, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax
Ronen Avner
Partner
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Sophie Matatyaho
Partner
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Yaniv Erlich
Partner
Corporate Tax, Employee Tax Benefits, International Tax Planning, Mergers & Acquisitions, Tax
Amit Shelef Fattal
Associate
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Aryeh Holtz
Associate
Corporate Tax, Employee Tax Benefits, International Tax Planning, Private Clients, Trusts & Estates, Tax
Roni Bar-Ze’ev
Associate
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Ilana Granditer
Private Clients, Trusts & Estates, Tax
Rotem Sheridan
Tax, Transfer Pricing
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