Israeli Tax Alerts | Practical Interpretations | 2008-2020

32 In this connection, it can be claimed that because of the temporary nature that the economic presence in Israel in the circumstances that are described above has, it cannot be determined that a permanent establishment arises in Israel for a foreign company. This also fits with the aspect of the determinations that are required for the existence of a permanent establishment in the tax treaties that the State of Israel has signed upon, and if the economic presence in Israel is temporary, all the more so in the circumstances that have been forced upon the project, the requirement in the said determinations is not met. (April 2020)