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
Herzog is delighted to have been ranked Tier 1 in 6 practice areas in Chambers Global 2018: Banking & Finance

Herzog Fox & Neeman Leads Israeli Market in 2018 Chambers Global Rankings
Further to our circular of December 12, 2017 regarding the new Voluntary Disclosure Procedure of the Israeli Tax Authority (the
Client Update | Israeli Tax Authorities Published New Guidelines for the Voluntary Disclosure Procedure
Herzog Fox & Neeman represented Israel Electric Corporation in a $1,000,000,000 international notes offering. The offering was successfully priced during

Herzog Fox & Neeman Represented Israel Electric Corporation in a USD 1 Billion International Notes Offering
In our client update of 23 November, 2017 (see here), we informed you about the new Israeli deemed distribution rules, which
Client Update | The Rise and Fall of the New Israeli Deemed Distribution Rules to Non-Israeli Affiliates
Under Israeli law, a taxpayer taking a certain tax position, is required to report it to the Israeli Tax Authority

Client Update | New Israeli Reporting Liabilities Relating to Foreign Residents, New Immigrants and Trusts
The following lawyers have been promoted to partner in 2018: Iris Achmon – Antitrust & Competition Department Ohad Elkeslassy – Commercial Department

Herzog Fox & Neeman is Pleased to Announce the Appointment of 15 New Partners | 2018
The Israeli Tax Authority (the “ITA”) published today (December 12, 2017) a new Voluntary Disclosure Procedure (the “VDP”) which shall
Client Update | Tax Authorities Published a New Voluntary Disclosure Procedure
The Israeli Tax Authority (hereinafter: “the ITA”) is currently preparing to replace the Custom Administration’s foreign trade system of Israel
Client Update | Assessments for the Replacement of the Custom Administration’s Foreign Trade Operation System of the State of Israel and the Implications for Import Processes
New Israeli Income Tax Ordinance section 3(i1), enacted on December 29, 2016 and effective January 1, 2017, states that a
Client Update | New Israeli Deemed Distribution Rules – Consider Action Before Year End
“The Israeli Tax Authority (the “Authority”) recently published a draft proposal regarding positions that must be reported, including indirect taxes

Class Action on Indirect Taxes – State Exposed and Cornered | Opinion by Iris Weinberger
Recently, the Israeli Tax Authorities (the “ITA”) published a press release introducing a new “Green Lane” which is intended to
Client Update | Israeli Tax Authorities Introduce a New “Green Lane” For Transferring Funds Abroad For Investment Purposes Without Tax Withholding
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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