International Tax
This category should begin with a fuller overview of International Tax in Israel rather than a short label and a grid of links.
Tax Treaties
Israel has signed tax treaties with over 50 countries to prevent double taxation and facilitate cross-border trade. This section explains how treaties work, the key provisions (reduced withholding rates, permanent establishment rules, tie-breaker clauses), how to claim treaty benefits, and a list of Israel's current treaty partners.
5 articlesForeign Tax Credits
Israeli residents who pay taxes abroad on foreign-source income can often claim a foreign tax credit to avoid double taxation. Understand how the credit system works, the per-country and per-basket limitations, which foreign taxes qualify, how to document credits, and the interaction between credits and treaty benefits.
5 articlesCFC Rules
Israel's Controlled Foreign Corporation (CFC) rules prevent Israeli residents from deferring tax by holding passive income in low-tax foreign companies. Learn when CFC rules apply, which income types are captured, how the deemed dividend is calculated, available defenses, and reporting obligations for shareholders of foreign companies.
5 articlesTransfer Pricing
Transfer pricing rules require that transactions between related Israeli and foreign entities be conducted at arm's length prices. This section explains the arm's length principle, accepted pricing methods (CUP, cost-plus, TNMM), documentation requirements, the transfer pricing study process, and penalties for non-compliance.
5 articlesForeign Workers
Foreign workers in Israel — including short-term assignees, experts, and migrant workers — are subject to special tax rules. Learn about the tax obligations for non-resident workers, employer withholding requirements, social security totalization agreements, available tax treaty benefits, and the process for obtaining tax residency certificates.
5 articlesIsraelis Abroad
Israeli citizens and residents living or working abroad remain subject to Israeli tax on their worldwide income unless they formally terminate their tax residency. This section covers the tax implications of relocating, how to establish non-resident status, ongoing reporting obligations, social security considerations, and the process for resuming residency upon return.
5 articlesAnti-Avoidance
Israel has enacted several anti-avoidance measures to combat aggressive international tax planning. These include general anti-avoidance rules (GAAR), substance-over-form doctrines, the taxation of artificial arrangements, rules against treaty shopping, and information sharing with foreign tax authorities. Understand what arrangements the Tax Authority may challenge.
5 articlesInternational Structures
Israeli businesses and investors often use international corporate structures to manage global operations. This section reviews common structures — holding companies, IP-holding entities, regional headquarters, and foreign subsidiaries — and their tax implications under Israeli law, including CFC exposure, withholding tax obligations, and treaty planning opportunities.
5 articlesForeign Investment
Foreign investors in Israel benefit from a welcoming tax regime that includes tax treaties, reduced withholding rates, and incentive programs. This section covers the tax treatment of foreign direct investment, portfolio investment by non-residents, repatriation of profits, and available incentives under the Investment Encouragement Law.
5 articlesInformation Exchange
Israel participates in international information exchange frameworks, including CRS (Common Reporting Standard) and FATCA. Financial institutions report account information of foreign tax residents to Israeli authorities, who share it with other countries. Understand your reporting obligations, what information is exchanged, and how this affects Israeli residents with foreign accounts.
5 articlesNew Immigrants
New immigrants (olim) and returning residents to Israel receive significant tax benefits during an adjustment period of up to 10 years. These include exemptions on foreign income, capital gains, and reporting obligations. Learn about the eligibility criteria, the scope of the benefits, how to plan your aliyah from a tax perspective, and recent changes to the benefits package.
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