Tax alert
International taxation
Amendment 168 to the ITA was designed mainly to absorb immigration to Israel; to bring back human capital and to encourage financially capable investors to become Israeli residents. Within this amendment different provisions were added "to preserve the new immigrants and\or veteran residents (hereinafter: "beneficiary...
As part of the benefits a new immigrant receives, he is entitled to a reduced purchase tax rates. This in accordance to the real estate taxation regulations (betterment, sale and purchase)-1974, indicating that a new immigrant would pay a reduced purchase tax of 0.5% up to a limit of about 1.4 million NIS. Beyond that limited...
The treaty between Israel and Georgia was signed in May 12, 2010. Like other new treaties Israel has signed lately (see tax alert No 7), this treaty sets out rules that enables Israel's Competing abilities on an international level, as well as to encourage mutual investments. The treaty should enter into force on January 1st, 2011...
Similar to other countries around the globe that have a participation exemption regime, Israel has regulated participation exemption rules in relation to an Israeli holding company. Such company enjoys different exemptions, among others, exemption on capital gain when selling the shares of the companies it holds...
A Trust Holding Company ("Trust Company") is defined in the trusts section in the Israeli Income Tax Ordinance as: "A body of persons holding the trust assets for the trustee, directly or indirectly" - The definition indicates that the trust company is transparent and serves as a "vessel" to hold the trustee assets. The trust...
Israel is signed on social security treaties with many countries. These treaties regulate the social security rights of who ever emigrates from one country to the other to live there temporarily or permanently. The types of insurance regulated in the treaties are as follows: old-age, survivors, children, work injury, maternity, general...
According to section 64a to the Israeli income tax Ordinance, a family company is a company that its shareholders are all family members, who, according to the section, are seen as one person. From the tax standpoint, the income of the company is seen as if it was all produced by the "representative taxpayer"...
These days, the ordainments bringing the new treaties into force, as of January 1st, 2010, were signed. The new treaties are designed to improve the competing ability of many Israeli companies, operating in these countries over the past years, in areas such as technology and communications and to encourage mutual...
Recently an interesting taxation resolution, referring income from a family company to a new immigrant was published (Taxation resolution 1010/09). The case dealt with a couple, residents and citizens of a treaty country that considered immigrating to Israel and getting the status of "new immigrants". The couple owned a foreign...
After a further hearing the Supreme Court finally the Shadami rule was ratified (case 6811/04 ,dated 4/8/2009). The case that was discussed in Shadami deals with the day of purchase in combination transaction (i.e. a transaction where the property owner sells a part of his rights in the property to a contractor in exchange for...