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Insights & News / Hanna Daher

Supreme Court: Service to Foreign Residents May Be Subject to Full VAT

The Supreme Court noted that, by its nature, the essence of a brokerage transaction is joining two parties into one transaction. Therefore, treating the transaction as providing a service to each party separately—a foreign resident and an Israeli resident—does not reflect the true economic essence of the service.

Imputed Value on Usage of Company Car as Income during Swords of Iron War

As a rule, employers in Israel that provide company cars for their employees’ use must attribute income to those employees in accordance with the imputed value of the use of the car prescribed in the Income Tax Regulations. Moreover, even if the car was in the employee’s possession for only part of the month, employers must attribute income to the employees for the full imputed value of the use of the car. However, the Israel Tax Authority has issued new special instructions because of the Swords of Iron War.

How to Gain a Tax Credit before the Year’s End

Hanna Daher, a partner in our firm’s Tax Department, was interviewed by Globes, along with a number of other tax experts, about end-of-the-year tax tips . Hanna noted the tax credits that individuals or business owners can obtain if they donated over NIS 200 this year to a public institution.

Categories: Private Clients | Tax

Swords of Iron: Compensation Outline for Businesses Law

After lengthy discussions, the Knesset approved a wartime compensation outline for businesses. The outline offers compensation of up to a maximum of ILS 1.2 million to businesses with annual turnovers ranging between ILS 12,000 and ILS 400 million.

Ruling: Pre-Sale Dividend Distribution to Reduce Tax Liability

Legitimate tax planning or an artificial transaction to reduce tax liability? Israeli court ruling on a dividend distribution prior to a sale of shares or holdings of a company.

Israeli High-Tech: “Angels Law” Grants Tax Benefits to Investors

Israel’s new "Angels Law" grants tax benefits to investors in Israeli startups, and in the Israeli high-tech industry in general, with the goal of spurring the growth of high-tech companies based in Israel or whose intellectual property is registered in Israel.

Investments via SAFE as a Tax Event

For the first time, the Israel Tax Authority has announced its position regarding investments via SAFEs. It determined that, under particular circumstances, the investment is to be considered an advance on a share investment account.

Corporate Inversion – Turning an Israeli Company into a Foreign Company

A corporate inversion is a process of changing a company’s holding structure, largely with the intention of turning an existing company into a foreign company by positioning a foreign company as a parent company of the Israeli company and enabling the Israeli company to expand into new markets in the international arena.

Reporting Methods – “Accrual Basis” or “Cash Basis”

Preparing reports on an accrual basis and adjusting them to a cash basis for tax purposes was an acceptable practice until the Israel Tax Authority (the "ITA") determined otherwise. However, many companies still prepare two sets of reports, sometimes resulting in problems with the ITA.

Tax Plan and Acquisition of a Public Shell

The Israeli tax authorities are examining acquisition transactions, inter alia, to ensure they are not artificial transactions intended for offsetting losses. Transactions acquiring public shells are no exception in this regard.

Determining Intellectual Property Value for Israeli Tax Purposes during a Sale between Related Parties

A sale of intellectual property between related parties requires advance planning and preparation in order to avoid tax exposures in Israel.

District Court: Changing a Business Model after Purchasing Company Shares Does not Always Constitute a Tax Event

The Israeli court's ruling further details and explains the complicated tax issues that may arise from business restructuring and from transactions that create such restructuring.

 

Shift 4 Acquires Israeli Clearing Technology Company Finaro

Shift4 Payments, an American public company, has acquired Finaro for a value of USD 575 million.

 

Advs. Simon Jaffa, Ariella Dreyfuss, Mayer Winkler, Harel Perlmutter, Hanna Daher, and Fadi Atallah advised on the transaction.

 

Categories: Corporate | FinTech | High Tech | Mergers and Acquisitions

Representing Reef Technology in Acquisition of Israeli Startup Bond

We advised Reef Technology, one of the largest operators of mobility, logistics hubs, and neighborhood kitchens in the United States, on its acquisition of the Israeli logistics startup Bond, which was initially founded as Shookit, a direct-to-consumer grocery startup that delivered fresh produce to clients in the city within hours. The deal was led by Advs. Michael Barnea, Ariella Dreyfuss, and Tal Freilich. Netta Bromberg advised on the employment side. Harel Perlmutter and Hanna Daher advised on the tax side. Anat Even-Chen advised on data privacy and security and other regulatory matters.

Categories: Corporate | Investments | Mergers and Acquisitions

Taxation of Hedge Funds in Israel – A Short Guide to the Perplexed

A hedge fund is an entity comprised of several investors seeking to invest in financial assets to achieve a common profit, where the execution of the investment may change from one fund to another, in accordance with the investment strategies put in place by the fund manager.

Tax Advice on USD 20 Million Investment in CyberMDX

Our tax team advised the strategic partner Sham (Relyens Group), Europe’s largest insurance and risk management provider for healthcare, on the tax aspects of its USD 20 million investment in CyberMDX, an Israeli healthcare cybersecurity provider that delivers visibility, threat prevention, and operational efficiency for medical devices, IoT, and clinical networks.

Categories: Tax

Amending Protocol to Israel-UK Tax Treaty to Take Effect in Early January 2020

An amending protocol to the 1962 Israel-UK tax treaty is effective as of January 1, 2020.The protocol includes a long list of significant and fundamental amendments and updates.

The End of Sanction-Free Voluntary Disclosure

The sanction-free voluntary disclosure procedure will come to a close at the end of 2019. Provided the Israel Tax Authority and the State Attorney’s Office decide not to extend this procedure, this may be the last opportunity to declare and report true income, and accordingly pay true taxes, without the disclosure being subject to criminal sanctions.

Barnea Represented CryoLife in a Strategic Transaction with the Israeli Medtech Startup Endospan

Our firm represented CryoLife in a strategic transaction with Israel-based endovascular stent graft system developer Endospan. The transaction involved an option to purchase Endospan for up to USD 450 million in the future, together with an exclusive distribution arrangement and USD 15 million in secured debt financing.

 

 

Categories: High Tech | Investments | Life Sciences

Barnea Represented Exclusive Networks in Securewave Acquisition

Our firm represented Exclusive Networks in its acquisition of 70% of the shares of Israeli company Securewave Ltd, one of Israel’s leading independent cybersecurity VADs.