Client updates / Tax

An Israeli district court ruled, for the first time, that distributable profits may be recognized even when a company has a balance of accumulated losses, provided that the profits accumulated during the holding period actually contributed to reducing the accumulated loss, even if the company ultimately had no surpluses.

In November 2025, the OECD published an update to the interpretation of the OECD Model Tax Convention to address contemporary business practices in today’s environment. The update addresses, inter alia, how permanent establishment rules should be interpreted in the context of remote work and work performed from another country.

If you participated in Mehir LaMishtaken tenders and paid purchase tax, we recommend promptly reviewing whether you may be eligible for a purchase tax rebate. We are at your service to perform a preliminary eligibility review based on the tender documents, lease contract, special conditions appendix, and construction contract.

A settlement was approved recently within the framework of two class actions, which may result in some taxpayers receiving considerable financial refunds, while specifically re-examining the taxation of additional development expenses. Those entitled to a refund must forward the Refund Documents to the class plaintiff’s attorney within 180 days of the settlement approval date. The ITA will transfer the refund due to each class member within 150 days of the date of receipt of the documents.

On December 31, 2025, Israel enacted legislation imposing a minimum corporate tax on multinational groups, which applies to Israeli resident entities that are members of an MNE as of the 2026 tax year.

The recently published draft bill seeking to reinstate property tax could have a significant impact on dozens to hundreds of thousands of landowners in Israel. Although only a draft bill at this stage, it is advisable to understand the potential changes, whether they affect you, and how to prepare in advance to reduce exposures and avoid surprises.

At the end of October 2025, the Tel Aviv District Court issued a precedent-setting ruling in the Hexadite case, which deliberated fundamental issues relating to transfer prices and the appropriate way to determine the value of assets in restructuring transactions between related parties. This ruling is particularly relevant for multinational companies in Israel that carry out complex acquisition, sale or restructuring transactions, since it clarifies how these complexities should be resolved in practice, particularly within the context of tax gross-up, holdback payments and secondary adjustments.

On August 25, 2025, the Israel Tax Authority (ITA) published a new directive entitled “Voluntary Disclosure Procedure – Temporary Order.” The aim of this procedure is to encourage both Israeli and foreign residents who have committed tax offenses under Israeli law to correct their filings and submit truthful reports.

On April 2, 2025, US President Donald Trump announced his intention to impose reciprocal tariffs of 10% on all goods imported into the United States, and higher “special reciprocal tariffs” on imports from several countries with whom the United States has a large trade deficit.

On July 1, 2025, a memorandum of law was published for public comments proposing an amendment to the Israeli Income Tax Ordinance’s definition of “Israeli resident” for tax purposes. The amendment proposes to replace the rebuttable presumption with irrebuttable conclusive presumptions about whether an individual is an Israeli resident or a foreign resident

A recent district court ruling broadened the interpretation of the statutory provisions governing exemptions from land appreciation tax and ruled that transfers of shares of a real estate association as a gift between siblings are exempt from capital gains tax even if the shares were not direct gifts from the parents but originated from land received as a gift from them. The court also prescribed several important procedural rules to improve the protection of taxpayers’ rights vis-à-vis the Israel Tax Authority (ITA).

Upon the launch of Operation Rising Lion last Friday, the Minister of Defense declared a special national state of emergency in conformity with the Civil Defense Law, 1951. On Sunday, the government extended the state of emergency until June 30, 2025.

Owners of buildings designated for long-term rentals are entitled to significant tax benefits that are being granted in order to encourage the construction of buildings that include residential apartments earmarked for long-term rentals.

Israeli tax ruling on the question: The Committee deliberated the North Mall appeal and ruled recently that a “partial cancellation” of a real estate sale transaction is, in fact, a new transaction subject to additional tax

In February 2025, the Israeli Tax Authority published an Income Tax Circular outlining the conditions and principles of the new Angels Law, focusing on the tax benefits granted to investors in early-stage companies that qualify as R&D companies.

As of 2025, an additional 2% surtax will be imposed specifically on taxable capital income (income from dividends, interest, capital gains from real estate sales and other capital sources) exceeding the maximum of ILS 721,560. This means that taxable capital income exceeding the maximum will now be subject to an inclusive surtax of 5%.

At the end of 2024, the Knesset enacted significant legislative updates within the framework of the Arrangements Law that completely revamp how “closely held companies” are taxed in Israel.

A new draft bill for second and third readings aims to ease tax relief conditions in corporate restructuring. Initially part of the 2025 Arrangements Law to support high-tech, it was later split from the original bill.
A new draft bill for second and third readings aims to ease tax relief conditions in corporate restructuring. Initially part of the 2025 Arrangements Law to support high-tech, it was later split from the original bill.

The Israel Tax Authority (ITA) recently published updated guidelines, regarding tax aspects applying to investments in companies through SAFEs. Such guidelines were published following the previous guidelines published by the ITA during May 2023, and which expired at the end of 2024.

The Israel Tax Authority (ITA) recently published an addendum to the 1987 circular with the goal of minimizing disputes with sellers of residential apartments.