Tax alert

International taxation

As is well known, a foreign company will be deemed to be a company that is resident in Israel, if the control of its business and the management thereof are operated in Israel even though it was
n these frenzied days, most of the citizens of the country are under curfew in their homes, following directives or recommendations that have been issued by the Ministry of Health. Furthermore and in light of the circumstances, most business people are now located within the borders of the State of Israel, even though in normal circumstances they are in the habit of staying out of the country for business
e wish to inform you in brief that due to the Corona crisis, the following are the benefits provided by the governmental National Insurance Institute of Israel ("the NIII"): •Employees who leave on furlough are entitled to unemployment benefits (under certain conditions, in particular, a six-month employment period of one-and-a-half years before the furlough). The NIII will provide an unemployment wage to the mentioned unemployed.
Over the last decade many Israeli residents have sought to settle previously unreported accounts of foreign - held assets and the income generated by them with the Tax Authority. This was typically performed by a formal petition to the Tax Authority via the Voluntary Disclosure Procedure. The procedure has changed over the years, has been extended periodically, and even allowed for submission of anonymous requests and negotiations until an arrangement was reached.
The Tax Authority has just published a tax ruling (decision 4429/19), about VAT obligations for services rendered to a foreign resident via operation and management of a website advertising products of foreign suppliers abroad that provides links (affiliation) to the supplier websites abroad for purchase. The taxation decision states that full VAT applies to income from these services despite the rule that a zero rate VAT applies to services provided to foreign residents.
Over the last decade many Israeli residents have sought to settle previously unreported accounts of foreign-held assets and the income generated by them with the Tax Authority. This was typically performed by a formal petition to the Tax Authority via the Voluntary Disclosure Procedure. The procedure has changed over the years, has been extended periodically, and even allowed for submission of anonymous requests and negotiations until an arrangement was reached.
n April 2018 a (unanimous) ruling was handed down by the Supreme Court on two different appeals, which deal, inter alia, with the application of the section that deals with transfer pricing, in respect
ecently (in May 2019), a judgment was handed down, which the crypto industry had been anticipating (but not the result that was determined in it), pursuant to which a Bitcoin is deemed to be "an asset" and not "a currency".
The chapter on trusts in the Israeli Tax Ordinance affords the status of a taxpayer for tax purposes to a trust (including a registration number, a managed file in an assessing office etcetera), even though the trust itself is not an independent legal entity but is rather a legal arrangement, generally between a settlor and a trustee.
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