International taxation - Delek Hungary ruling (profits available for distribution in a foreign company) – insights into international taxation
The Delek Hungary court ruling has recently been published. The ruling (and the analysis it raises) is quite fascinating, but without going into the details of all issues raised, we feel it's important to mention here that ultimately, the court preferred to take the perspective of the objective at the basis of the various legal provisions rather than adhering to the letter of the law.
International taxation - Israeli tax ramifications of token offerings (ICOs) for foreign companies, and more...
The world of cryptocurrencies is characterized by rapid change and extreme volatility. The moods of active crypto players swing in keeping with the surprising fluctuations of coin values. Our office has met with dozens of such clients, and in recent months with quite a number of groups who
International taxation - Granting options whose vesting is exit event dependent to employees on relocation
Several weeks ago a (consentual) tax ruling was published on the subject of employee options – voiding options that at the time of vesting were dependent on an exit event and reissuing them on the "trustee capital gains" track (a track in which the benefit value is not recognized as a tax deductible expenditure by the company, and the employee is subject to capital gains tax – limited
The Tax Authority's first taxation decision on cryptocurrency was published this week, concerning record keeping of receipts from service provision received with decentralized coins. This decision was led by our office.
The digital currency scene has heated up in 2017 due to the great increase in value of digital currencies, as well as significant developments in the area – primarily the wave of new "token" offerings that have joined the existing ones; as a result, today's trading platform includes some 1,600 different currencies.
International taxation - Company or branch office? Considerations in determining the legal entity for business operations in Israel or abroad
A question that often arises when considering a legal entity for international business operations is whether to set up a subsidiary in a foreign country or a branch office (i.e. permanent establishment); that is, direct company operation in the target country. This question also arises among foreign clients wishing to operate in Israel.
The Israel Supreme Court announced its ruling this month on the case of Gmul America Ltd. (CA 8934/16), concerning interpretation of Article 26, Relief from Double Taxation, of the Israel-US Tax Treaty (hereinafter the "Treaty"). The ruling overturned the District Court's decision on the case (Tax Appeal No. 49525-02-14).
International taxation - Business investments – insight from taxation decisions on the subject of permanent establishment for foreign investors
Many entrepreneurs wish to direct their available capital to investment in Israeli companies in a variety of areas, in particular – the Israeli high-tech sector, known to be one of the central growth engines of the economy. Government
International taxation - Sale by a new immigrant or returning resident of shares in a foreign company, part of whose value is derived from Israeli assets
As part of the list of reportable tax positions published by the Tax Authority, a position has been added on the sale by an individual who immigrated to Israel either for the first time or after a period of 10 years or more (such a "beneficiary individual" has a 10-year exemption from
International taxation - A last-minute declaration of the Tax Authority's position on taxation of "virtual currencies"
The Income Tax Ordinance stipulates the taxpayers obligations to report in their tax return whether they have taken a "reportable tax position". The Tax Authority has added a position entitled "taxation of virtual currencies" to that list. The Tax Authority indicates there that