CFC
A foreign holding company of an Israeli resident may be considered a 'controlled foreign company' (CFC) and its profits will be attributed to the Israeli shareholder.
exceptional
If the foreign company is active (active income) and not just holding assets - CFC rules will not apply.
Important Note: The information on this website is for general informational purposes only and does not constitute professional tax advice. Consult a qualified tax advisor before making financial decisions.