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Insights & News / Itiel Shloush
Court Ruling on Valuing Restructuring Transactions: Tax Gross-Up, Holdback, and Secondary Adjustments
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.
Israel or Foreign Resident? New Memorandum of Law Changes the Rules
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
Tax: Classification of Intercompany Transactions
A tax assessment dispute in Israel has led to a new court ruling dealing with relationships between subsidiaries in a multinational group and classification of the nature of the business activities that the companies provide to each other.