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.
Meir Linzen
Chairman
Tax News & Insights
We are pleased to announce that Herzog represented Airobotics in its acquisition by Ondas. Ondas will acquire all of the

Herzog represented Airobotics in its acquisition by Ondas
We are very proud to have represented Bank Leumi in its $500 million international senior notes offering. This is the

Herzog represented Bank Leumi in its $500 million international senior notes offering
Dear clients and friends, The Law for the Reduction in Use of Cash, 2018 (the “Law” or the “Cash Law”)

Reduction In Amounts Permitted to be Paid in Cash as of August 1, 2022
Congratulations to our client, Berkshire Partners, on its acquisition of a 49% stake in MedOne, a leading data center operator

Congratulations to our client, Berkshire Partners, on its acquisition of a 49% stake in MedOne
Congratulations to our client, Graphyte, the UK-based marketing personalization platform for the gaming industry, in its acquisition by Optimove, a

Congratulations to our client, Graphyte on in its acquisition by Optimove
Following on from our updates in March and April of this year, on June 14th, 2022 the Finance Committee of

Finance Committee Approves Master File and CbCR Regulation Changes and other TP Requirements
Dear friends and colleagues, As a follow-up to our client update from February 16, 2021, we would like to update you that a

New Directive Regarding Returned Exports and Temporary Entry
Dear Clients, Colleagues and Friends, The Tel-Aviv District Court recently issued its ruling in the Medingo case in which the

New Israeli Ruling Rejects Tax Authority’s Position Regarding Change of Business Model
Following on from our recent update, on 4 April 2022, our firm participated in the next stage of discussions, on

Legislation Updates: TP Study Requirements, Master File and CbCR
On 9 March 2022, our firm participated on behalf of the Israeli Bar in a discussion held in the Finance Committee of

Israeli Parliament Discusses Master File and CbCR implementation
5 tips on how to choose the right UAE free zone for your business Nitzan Ben-nun Tech and System senior

Have you asked yourself why so many flock to the UAE’s shores to do business?
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)
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
Eyal Bar-Zvi
Partner
Commercial, Hi Tech, International Tax Planning, Mergers & Acquisitions, Tax, Transfer Pricing
Itamar Gur
Partner
Corporate Tax, International Tax Planning, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax
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
Rotem Sheridan
Tax, Transfer Pricing
Aryeh Holtz
Associate
Corporate Tax, Employee Tax Benefits, International Tax Planning, Private Clients, Trusts & Estates, Tax
Mordechai (Moti) Fogel
Associate
Indirect Taxes, Customs & International Trade, Tax, Value Added Tax (VAT)
Roni Bar-Ze’ev
Associate
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
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