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Insights & News / Harel Perlmutter

Dun's 100 Forum for Senior Tax Professionals 2026

Harel Perlmutter, a partner and head of our Tax Department, participated in the Dun's 100 Forum for Senior Tax Professionals 2026, where senior tax professionals discussed key developments in Israeli tax policy. The discussion addressed the implications of the retained earnings reform, the challenges of the 2027 budget, changes to VAT collection mechanisms, tax policy affecting the high-tech sector, and the impact of AI and digitalization on taxation. Harel addressed permanent establishment issues in light of the new legislation, as well as changes affecting new immigrants and returning residents.

Categories: Tax

Landowners May Be Subject to Property Tax in Israel!

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.

Offsetting Losses Against Gains: An Effective Tool for Significant Tax Savings

Adv. Harel Perlmutter, a partner and head of the firm’s Tax Department, was interviewed by Globes about offsetting losses against gains, one of the most effective planning tools for tax optimization, which can result in substantial savings for investors. This is a limited-time opportunity, however, as the option to do so will close with the end of the current tax year.

Categories: Tax

Investor Event at Barnea in Collaboration with WeCcelerate & Firefly

We hosted an investor event in collaboration with WeCcelerate and Firefly. The event featured presentations of innovative ventures across various sectors, including pharmaceuticals, mental health, advanced technologies, and digital innovation. During the event, Adv. Harel Perlmutter, head of the firm’s Tax Department, delivered a lecture on tax due diligence in investment and acquisition transactions, addressing key considerations relevant to investors and entrepreneurs. 

 
Categories: High Tech | Start Ups | Tax

DDoS Community x Barnea: A Professional Event Bridging AI, Innovation, and Law

Adv. Harel Perlmutter, a partner and head of the firm's Tax Department, spoke at an event held in collaboration with the DDoS community, a network connecting members of the ultra-Orthodox community with the high-tech industry. His lecture focused on practical insights for tech employees regarding compensation, equity, options, and their related tax implications. The event also featured two technology-focused talks by community experts on AI and innovation.

Categories: High Tech | Start Ups | Tax

Adv. Harel Perlmutter on Walla News: Upcoming Voluntary Disclosure Procedure for Digital Assets

Adv. Harel Perlmutter, a partner and head of the firm's Tax Department, was interviewed by Walla regarding the Israel Tax Authority’s upcoming voluntary disclosure procedure for holders of cryptocurrencies and digital assets. The new framework is expected to offer immunity from criminal proceedings for taxpayers who come forward, without an anonymous track and without relief from interest or inflation adjustments. The procedure will apply to assets such as Bitcoin, Ethereum, and NFTs, provided the disclosure is made before any investigation is initiated or relevant information reaches the authorities.

Categories: Blockchain | Financial Regulation | Tax | Taxation of Cryptocurrencies

Residency in Israel: When and Why Should You Contact the Israel Tax Authority to Obtain a Ruling?

New immigrants and returning residents are entitled, by law, to a tax exemption on income originating outside of Israel for a period of ten years after they become Israeli residents. In particular instances, we recommend applying for a tax ruling from the Israel Tax Authority (ITA), especially when the date of receipt of new immigrant status differs from the date of the actual relocation of center of life to Israel.

Israel Bar Association Tax Conference: Adv. Harel Perlmutter and Adv. Maya Carmi

Adv. Harel Perlmutter and Adv. Maya Carmi Lubartovski from our firm participated in the Israel Bar Association's (Southern District) Tax Conference. The conference covered various aspects of taxation, including real estate tax, income tax, and VAT. Harel and Maya participated in a panel on trust taxation, discussing the practical application of trust taxation (income tax and real estate tax) and how it is actually carried out in practice.

Categories: Tax

Adv. Harel Perlmutter on Channel 12 News: Largest Exit in Israeli High-Tech History

Adv. Harel Perlmutter, a partner and head of the firm's Tax Department, was interviewed on Channel 12, Israel's main news channel, regarding the largest exit in Israeli high-tech history. He discussed the tax implications of the deal, stating that "between ILS 12 and 16 billion will flow into the state's coffers, covering nearly 10 percent of the national deficit with this deal alone."

Categories: Tax

Navigating Tax Challenges in Startups

In an article for B'Chadrei Charedim, Adv. Harel Perlmutter, head of the firm's Tax Department, highlights how strategic planning can help minimize costs and optimize financial outcomes.

Categories: International Taxation | Start Ups | Tax | Tax Incentives and Grants

Tax Innovations in Israel in 2024

Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their efforts in the legislative arena and issued several significant tax rulings. Following are the most important innovations relating to income tax, real estate tax and VAT.

International Inheritance Tax Planning: Adv. Harel Perlmutter Interview on “Disputes Program”

Adv. Harel Perlmutter, head of our firm’s Tax Department, was interviewed by Yigal Borochovsky and Rachel Shahar for 102FM’s “Disputes Program.” He explained the procedures and necessary reporting when receiving an inheritance from outside of Israel.

Categories: Tax

Osem Continues to Transfer IP Rights to Nestle

Adv. Yuval Lazi and Adv. Harel Perlmutter were interviewed by Globes about the transfer of Osem’s intellectual property rights to Nestlé. They explained how this transfer is likely to affect the State of Israel.

Categories: Corporate | IP and Licensing | Tax

Tax Reliefs – Operation Swords of Iron

The Israel Tax Authority is publishing a series of tax reliefs to help companies and individuals and the current defense and civilian efforts.

Conference: The High-Tech Employment World

We hosted members of the Association of Corporate Counsel (ACC) for the conference, "The High-Tech Employment World." The conference focused on key issues in Israel's high-tech employment market and featured lectures on topics including non-compete clauses in employment agreements, the workforce as a critical element in the workplace, and more. Speakers included Adv. Micky Barnea, our firm's managing partner; Nani Maoz, Founder, Chairman, and CEO of Everest; and firm partners Adv. Harel Perlmutter, Adv. Netta Bromberg, Adv. Inbar Gorelick, and Adv. Amos E. Rosenzweig.

 




Categories: Employment | High Tech | M&A employment issues

Tax Guide for New Immigrants – Adv. Harel Perlmutter Article for MIGNEWS

Adv. Harel Perlmutter, the head of our firm’s Tax Department, details the tax benefits for new immigrants to the Russian language news website MIGNEWS.

Categories: Tax

Adv. Harel Perlmutter Serves as Speaker at Tax and Capital Market Conference 2022

Adv. Harel Perlmutter, head of our firm’s Tax Department, served as a speaker at the Israeli Association of Public Companies’ annual Tax and Capital Market Conference, where he discussed tax challenges for 2023.

Categories: Tax

Important Tax Tips from Adv. Harel Perlmutter

It’s important to prepare yourself for the end of the tax year and be aware of all the benefits you may be eligible for. An expert in the tax field, Adv. Harel Perlmutter suggests to Mako readers that they check their eligibility for Covid-19 grants and stresses that income from renting a residential apartment is taxable.

Categories: Tax

Podcast: Adv. Harel Perlmutter Talks Real Estate Taxation on "Kesef Bakir"

Taxation can make or break real estate deals. Adv. Harel Perlmutter, the head of our firm's Tax Department, spoke with Guy Lieberman about tax hitches and opportunities in an interview also published in Globes.

 

Categories: Real Estate | Real Estate Taxation | Tax

No Freebies? Adv. Harel Perlmutter Interview with "Tzeva Hakesef"

Many companies and businesses work with influencers to advertise their products on social media. This type of cooperation has tax implications. Adv. Harel Perlmutter, the head of our firm's Tax Department, was interviewed for the podcast "Tzeva Hakesef" (with Yair Weinreb) about the issue.

Categories: Tax

Adv. Harel Perlmutter Featured on “Tzeva Hakesef” Radio Program

Adv. Harel Perlmutter, the head of our firm’s Tax Department, was interviewed on the radio program “Tzeva Hakesef” about the latest storm surrounding apartments registered in the name of social media personality Hadar Mokhtar. Harel explained the issue and discussed the tax implications of registering an apartment in your child's name.

Categories: Tax

Real Estate and Taxes: Adv. Harel Perlmutter Op-Ed in Mako

Adv. Harel Perlmutter, the head of our firm’s Tax Department, discusses the "tax pitfalls" when purchasing an apartment for investment.

Categories: Tax

Taxes: Adv. Harel Perlmutter Lectures at Tel Aviv University

Adv. Harel Perlmutter, the head of our Tax Department, lectured this week to TAU Ventures, Tel Aviv University's venture capital fund for investments in startups. Harel addressed the advantages and disadvantages of preferred stock companies, employee compensation options, and other tax issues relevant to startups.

Categories: Tax | Tax Incentives and Grants

Hosting a Space Technology Delegation with Business France

Our firm hosted a delegation of French aerospace technology companies. Firm partners Adv. Samuel Henry Samuel and Adv. Harel Perlmutter discussed various aspects of entering the Israeli market.

Categories: High Tech

Oligarchs, Sanctions, and Money Transfers – Adv. Harel Perlmutter in Sunday Times

Is Israel a tax haven for Russian billionaires? Our firm's Adv. Harel Perlmutter and other experts shed light on what is happening.

Categories: Tax

Shift 4 Acquires Israeli Clearing Technology Company Finaro

Shift4 Payments, an American public company, has acquired Finaro for USD 575 million. Adv. Simon Jaffa, Adv. Ariella Dreyfuss, Adv. Mayer Winkler, Adv. Harel Perlmutter, Adv. Hanna Daher, and Adv. Fadi Atallah advised on the transaction.

 

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

Representing Shareholders in Startup's Acquisition by Vontier

We represented Inven Capital, Volvo Group Venture Capital, and Ombu Group in the sale of their shares in Driivz to Vontier, a global mobility company. Adv. Simon Jaffa, Adv. Ariella Dreyfuss, Adv. Harel Perlmutter, and Adv. Fadi Atallah advised on the transaction.

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

Tax Refunds for Salaried Employees

Tax refunds are not just a matter for the self-employed. In an interview with Israel Hayom to mark the end of the tax year, Adv. Harel Perlmutter, the head of our firm’s Tax Department, provides valuable advice on the subject.

Categories: Tax

Barnea Represents Sephira in Sale of Shares to DL Software Group

Barnea represented Sephira, a French-Israeli group of companies and a leading provider of software solutions for healthcare professionals, in the sale of its holdings to DL Software Group, recently acquired by the US private equity fund TA Associates. The transaction was led by Adv. Samuel Henry Samuel and Adv. Avihay Asulin. Adv. Netta Bromberg advised on all employment law matters, while Adv. Harel Perlmutter and Adv. Nir Ziman advised on all tax matters.

Categories: Corporate | Investments | Mergers and Acquisitions

Barnea Represents Reef Technology in Acquisition of Israeli Startup Bond

We advised Reef Technology, a leading US operator of mobility and logistics hubs and neighborhood kitchens, on its acquisition of Bond, an Israeli logistics startup originally founded as Shookit, a direct-to-consumer grocery delivery company that delivered fresh produce to customers across the city within hours. The transaction was led by Adv. Michael Barnea, Adv. Ariella Dreyfuss, and Adv. Tal Freilich. Adv. Netta Bromberg advised on employment matters, while Adv. Harel Perlmutter and Adv. Hanna Daher advised on tax matters. Adv. Anat Even-Chen advised on data privacy, cybersecurity, and other regulatory matters.

Categories: Corporate | Investments | Mergers and Acquisitions

“Pandora Papers” Scandal: N12 Interview with Adv. Harel Perlmutter

The “Pandora Papers” scandal, revealed yesterday, shines a spotlight on the world of tax havens. Adv. Harel Perlmutter, head of the firm's Tax Department, addresses the issue in an interview with N12.  

Categories: Tax

District Court Ruling: Azrieli Foundation Exempt from Paying Taxes on Dividends

An Israeli district court rejected the Israel Tax Authority’s attempt to force the Azrieli Foundation to pay taxes in the amount of tens of millions of shekels for dividends it received and continues to receive due to its holding in Azrieli Group's shares. The court accepted the tax appeal, which was filed by Barnea Jaffa Lande, and ruled that the Azrieli Foundation, a nonprofit organization that works for the public good in Israel, is not the controlling owner of Azrieli Group and is therefore entitled to a tax exemption. The court ruled, among other things, that the ITA’s position could have a chilling effect in relation to business entities’ support of philanthropic associations. Adv. Zohar Lande, Adv. Eyal Nachshon, Adv. Harel Perlmutter, Adv. Nir Ziman, and Adv. Omer Keydar represented the Azrieli Foundation throughout the proceedings, which lasted about five years.

Categories: Litigation | NPO | Tax

Renting Out Apartments in Israel and Abroad – Podcast with Adv. Harel Perlmutter

Are you renting out an apartment? It is important to understand the available tax tracks for rental income, the differences between the taxation of short-term and long-term rentals, and the rules applicable to renting out property abroad. In a comprehensive podcast hosted by Calcalist, Adv. Harel Perlmutter, partner and head of our firm's Tax Department, addresses these issues and discusses the taxation of residential rentals in Israel and abroad.

Categories: Tax

G7 Countries to Impose Global Minimum Corporate Tax Rate

Last weekend, the leaders of the G7 countries signed an agreement to impose a uniform global corporate tax rate of 15%. Adv. Harel Perlmutter, partner and head of our Tax Department, was interviewed by Calcalist about the decision and its impact on Israel.

Categories: International Taxation | Tax

Five-Session Workshop with Unit 669 Alumni

Together with the Black Cat Family, an organization for the alumni of the IDF’s combat search and rescue extraction unit, we launched a five-session workshop to provide basic legal tools for entrepreneurs. As part of the sessions, we lectured on founders’ agreements, the employee hiring process, and how to build the right tax structure.

Categories: Start Ups

Will Raising the US Corporate Tax Rate Affect Israeli Companies?

The planned corporate tax rate hike in the United States has Israeli investors worried about further developments and the impact on Israeli companies. As an expert in the tax field, Adv. Harel Perlmutter was interviewed by Bizportal on the issue and its implications.

Categories: Tax

Av. Harel Perlmutter Op-Ed: Recognize Childcare Expenses for Tax Purposes

Adv. Harel Perlmutter, head of our Tax Department, published an op-ed in Globes highlighting the importance of making childcare expenses tax-deductible, particularly during the coronavirus pandemic.

Categories: Tax

Haifa District Court: Repurchasing of Shares Is Not a Tax Event for Remaining Shareholders

In a bold step, the Haifa District Court rejected the Israel Tax Authority’s position on a company’s repurchasing of shares, and in effect split with a ruling of the Tel Aviv District Court, who considered a similar issue several years ago.

Barnea Represents Topaz Family in Sale of Holdings in Keystone Group

Approximately a year and a half after Accelmed, the investment fund managed by Uri Geiger, announced the merger of its US-based portfolio company, Keystone Group, with Israeli company Paltop, controlled by Shmuel Topaz, Accelmed is acquiring all remaining holdings in Paltop for ILS 100 million. The transaction resolves the dispute between the Paltop and Accelmed investor groups. Our firm represented the Topaz family and Paltop’s investors.

 

Categories: Corporate | Employment | High Tech | M&A employment issues | Tax

Returning Residents: Welcome Back to Israel?

Each year, many returning residents arrive in Israel. Following the COVID-19 outbreak, the number of people seeking to return to Israel has increased even further. The process of returning to Israel is not simple, and returning residents face enormous difficulties as part of it. A Ynet article on the subject featured an interview with Adv. Harel Perlmutter, a partner and the head of the firm’s Tax Department. Harel explained: “Those who return to Israel after less than six years abroad have almost no tax benefits.” He added that “there is a great confusion about the rights and benefits returning residents are eligible to from the National Insurance Institute. Over the years, the benefits for returning returns have been cut back, and this has kept people away from the country.”

Categories: Tax

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.

Barnea Represents Cyberx Shareholder in Microsoft Acquisition

We represented Inven Capital, a Czech-based VC fund and a shareholder in Cyberx Israel, an Israeli IoT & ICS cybersecurity startup, in Cyberx's sale to Microsoft for USD 165 million. CyberX has gained tremendous customer growth, with a number of leading companies using its IoT security platform to protect their web facilities. Cyberx has raised about USD 48 million since its inception in 2013. This is Microsoft’s eighth acquisition in Israel in the last decade.

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

Tax Considerations for Returning Residents to Israel

Adv. Harel Perlmutter will speak at a webinar hosted by the nonprofit Toshav Chozer on tax considerations for residents returning to Israel. The coronavirus pandemic has added new complexity to an already challenging decision. Harel will discuss the tax rights and benefits available to returning residents.

 

Categories: Tax

Doing Business in Israel – Practical Law

This year, we were once again responsible for preparing the QA guide on doing business in Israel for the Practical Law website. The guide provides an overview of recent key developments that have affected doing business in Israel, including the legal system, foreign investment, employment, tax, competition, privacy, and IP.

Categories: Banking & Finance | Capital Markets | Corporate | Employment | Internet | Regulation | Tax

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

Israel’s Tax Agency Criticized for Tepid Response to Coronavirus

Adv. Harel Perlmutter was interviewed by Tax Notes International following criticism that the relief measures introduced by the Israel Tax Authority in response to the coronavirus pandemic do not provide sufficient support for taxpayers.

Categories: Tax

Israel Tax Authority Reliefs in Light of Coronavirus Pandemic

In light of the coronavirus pandemic affecting the economic market, the Israel Tax Authority has published several reliefs for taxpayers.

Court Rules an Employee whose Shares in a Company Are Held by a 102 Trustee Has No Shareholder Rights in the Company

The Haifa District Court recently held, in a precedential decision, that an employee who received shares in a company held by a trustee in accordance with section 102 of the Income Tax Ordinance has no shareholder rights.

Representing MAT Investment Holdings in Merger between Two Manufacturers of Control Valves from Kibbutz Industry

Our firm represented the Spanish multinational industrial group MAT Investment Holdings in the merger of its Israeli subsidiary Dorot Management Control Valves from Kibbutz Dorot with A.R.I. Flow Control Accessories, a company owned indirectly by Kibbutz Kfar Haruv.

Categories: Corporate | Investments | Kibbutz Sector

Event Invite: New International Standards for Internal Alert Mechanisms

Join us for a seminar on the new international standards for internal alert mechanisms. The EU whistleblower protection directive that came into force in December 2019 and trends in the US signal a new duty—the obligation to formulate an in-house mechanism that allows employees to report improper or unethical conduct. To date, such mechanisms have largely been the responsibility of large companies subject to heavy regulation, but this reality is about to change. To what extent is your organization ready for such a mechanism? Are there any accepted standards for such mechanisms?

Categories: Corporate

Do You Hold Digital Currencies? Learn about Tax Regulation in Israel

Over 2000 (yes, 2000!) types of digital currencies exist today. If you are developing, mining, investing in, or using digital currencies, you should watch our video for some clarifications on the topic.

Hosting the Florida-Israel Business Accelerator

Our firm hosted a meetup of the Florida-Israel Business Accelerator. Adv. Yuval Lazi and Adv. Harel Perlmutter met with participating startups and discussed the challenges and opportunities of working with the United States.

Categories: High Tech | International Taxation | Start Ups | 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.

Israel-Serbia Double Taxation Treaty to Take Effect in January 2020

The treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income between the government of Israel and the government of the Republic of Serbia is expected to take effect on January 1, 2020.

Israel-Australia Double Taxation Treaty Enters into Force on January 1, 2020

The Minister of Finance signed in December 2019 the order bringing the double taxation treaty into effect on January 1, 2020.

Meetup for Women in E-Commerce

Today, we hosted a meetup for female entrepreneurs in e-commerce. Adv. Harel Perlmutter and Adv. Anat Even-Chen spoke to participants about tax and regulatory issues that could affect their businesses.

Categories: E-commerce | Internet | Regulation | Tax

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.

World Tax 2020 Edition

We are proud to be ranked by International Tax Review for the 2020 edition of World Tax in the general corporate tax and private clients categories.

Categories: Private Clients | Tax

Barnea Represents CryoLife in Strategic Transaction with 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

Dramatic Decision on the Taxation of Trusts in Israel

The Tel Aviv District Court handed down a decision a few days ago rejecting the Israel Tax Authority’s (ITA) position on the conveyance of real estate properties to trusts. This decision dramatically changes the taxation of trusts in Israel.

Precedential Ruling on Taxation of Real Estate Conveyance to Trusts

Adv. Harel Perlmutter was interviewed by TheMarker following a precedential ruling by the Tel Aviv District Court, which determined that the conveyance of Israeli real estate to a trust is not a tax event. Harel noted that the ruling opens up many interesting ways to plan and manage intergenerational transfers of wealth and real estate, without tax being a negative factor and affecting the process.

 

Categories: Private Clients | Private Clients | Tax

Precedential Court Ruling on Option Plans for Employees

A precedential judgment was handed down on option plans for employees in respect of section 102 of the Income Tax Ordinance. The court ruled that when a tax assessor is notified of the allocation of options in accordance with section 102 and fails to respond within 90 days, the plan is approved and the assessor cannot later claim that this is not so, except in very exceptional cases.

Barnea Represents Bridgepoint in Acquisition of Qualitest

Our firm represented the private equity group Bridgepoint in the approximately USD 420 million acquisition of the Israeli software testing company Qualitest from Marlin Equity Partners.

Categories: High Tech | Investments | Tax

Bar Refaeli to Pay Taxes on Millions Earned Abroad

Following the ruling that Bar Refaeli must pay ILS 16 million in income tax, Adv. Harel Perlmutter, head of our tax team, spoke on a popular 103FM radio program. The Central District Court in Lod had rejected Refaeli’s appeal the previous day, upholding the Israel Tax Authority’s assessment of tax on millions of dollars she earned abroad. Refaeli argued that she had spent only six months in Israel during the relevant years and, as a foreign resident, owed no Israeli income tax on that income. Harel explained how tax residency is determined, a central issue in the dispute over whether Refaeli was an Israeli tax resident in 2009 and 2010. He also clarified the distinction between the civil tax case and the pending criminal charges.

Categories: Tax

Israel and Australia Signed a Double Tax Treaty

A double taxation treaty was signed between Israel and Australia in the end of March 2019, after years of prolonged negotiations, expectations, and wonder about the obstacles.

Barnea Represents 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.

Airbnb Hosts in Tel Aviv May Face Higher Property Taxes

Adv. Harel Perlmutter was interviewed by Bloomberg BNA following the Tel Aviv City Council's move to double property taxes on apartments rented for short-term tourism.

Doing Business in Israel – Practical Law

Barnea's Q&A guide to doing business in Israel was published by Practical Law. The guide provides an overview of recent key developments that have affected doing business in Israel, including the legal system, foreign investment, regulation, employment, taxation, and IP.

Hosting Participants of the EdStart Program

We hosted today participants of AWS EdStart, an educational technology (EdTech) startup accelerator. A number of partners from our firm spoke at the seminar, discussing topics such as founders' agreements, intellectual property, and the tax issues of startups.


Categories: Employee Tax Benefits | High Tech | IP and Licensing | Start Ups

Lecture: Tax 101 for Startups

Adv. Harel Perlmutter lectured today at Ben-Gurion University on startup taxation. The lecture was part of a course for MBA students in the Faculty of Management.

Categories: Start Ups | Tax

Tax Aspects of Business Restructuring - New Tax Circular

Recently, the Israel Tax Authority published a circular discussing business restructuring in multinational groups.

Israel Threatens to Tax Airbnb for Delisting West Bank Rentals

Adv. Harel Perlmutter was interviewed by Bloomberg BNA following Airbnb's decision to remove listings in the West Bank.

Categories: Real Estate Taxation | Real Estate Taxation | Tax

Barnea Represents Senetas Corporation in Investment in Votiro

Our firm represented Senetas Corporation in a USD 8 million investment in the Israeli cyber company Votiro Cybersec Global Limited.

Categories: Corporate | Cyber | High Tech | Investments | Mergers and Acquisitions

New Era in International Tax Treaties: Israel Signs the MLI Treaty

Israeli signed the The Multilateral Instrument (MLI) Treaty, which will come into effect on January 1, 2019. The treaty will affect both Israeli and international corporations operating in Israel and overseas.

Entrepreneurs, Pay Attention Now or Pay Later

It is vital that entrepreneurs pay attention to possible tax benefits and tax liabilities from a startup’s earliest stages. Click to read the four things you should pay particular attention to.

Israel Offers Fast Route to Restructuring in Nod to Startups

Adv. Harel Perlmutter, head of the Tax Department, was interviewed by Bloomberg BNA following the Israel Tax Authority's announcement of a new "Green Route" to make it easier for Israeli entrepreneurs to transfer corporate assets abroad.

Categories: International Taxation | Start Ups | Tax

Amazon Web Services VAT Policy in Israel Sets Global Precedent

Adv. Harel Perlmutter, head of the firm's Tax Department, was interviewed by Bloomberg BNA on Amazon's decision to start collecting and remitting value-added tax in Israel.

Categories: International Taxation | Tax

Israeli Supreme Court Rules: Option Allotment Expenses Must Be Included In The Cost Base Calculation

The Israeli Supreme Court recently ruled a judgment on the matter of high-tech companies Kontera Technologies Ltd. and Finisar Israel Ltd. The facts underlying this judgment are relevant to many technology and startup companies in Israel engaged in R&D services with their foreign parent companies, and which their revenue is being calculated using a Cost-Plus method.

Israel Tax Authority Demands ILS 156M from eBay

Adv. Harel Perlmutter was interviewed by Bloomberg BNA, following reports that the Israel Tax Authority is demanding ILS 156.6 million in additional taxes from eBay for the 2010-2015 tax years.

Categories: International Taxation | Tax

Hosting Taasiyeda Participants for Lecture on Startup Essentials

Our firm is hosting today the participants of Taasiyeda, an education program founded by the Manufacturers Association of Israel, for a seminar on founders' agreements, IP, and tax issues.

Categories: High Tech | Intellectual Property | Start Ups | Tax

Spinoff May Trigger Tax Bill for Bezeq, Israel's Telecom Giant

Adv. Harel Perlmutter was interviewed by Bloomberg BNA on the possible governmental decision to force Bezeq Israeli Telecommunication Corp. to sell its infrastructure holdings in an effort to boost competition in the sector. This move may be considered a taxable event.

Categories: Corporate | Tax

Barnea Represents Greenyard Fresh in Acquisition of Mor International

Our firm represented Greenyard Fresh, a global market leader of fresh, frozen, and prepared fruits and vegetables, in the acquisition of 49% of Mor International.

Categories: Corporate | Mergers and Acquisitions

New Court Ruling Considers Tips Part of Waiter's Salary

Adv. Harel Perlmutter, the head of our Tax Department, was interviewed by Bloomberg BNA following a new labor court ruling that considers tips paid to waiters to be part of their salary, thus forcing employers to pay social benefits.

Categories: Tax

Israel Wants to Be First Country to Collect Tax Via Airbnb

Adv. Harel Perlmutter, the head of our Tax Department, was interviewed by Bloomberg BNA following the announcement of Israel's plans to tax Airbnb hosts directly through the service’s website. 

Categories: Real Estate Taxation | Real Estate Taxation | Tax

What Is the Milchan Law? Interview with Adv. Harel Perlmutter

Adv. Harel Perlmutter, the head of our Tax Department, was interviewed by Bloomberg BNA following recent coverage of the Milchan Law, which grants new immigrants and returning residents a 10-year tax exemption on income earned abroad.

Categories: Tax | Tax Incentives and Grants

Tax Authority Defines Rent Earned from Leasing 10 Apartments or more as Business Income

The Israel Tax Authority (ITA) recently published a draft circular for public comment on the issue of classifying residential rent income. The ITA states that, according to its reasoning, income from the leasing of 10 or more apartments should be deemed business income.

Israel Hopes Lower Taxes, Less Regulation Will Spur Trading Boom

Adv. Harel Perlmutter, the head of our firm's Tax Department, was interviewed by Bloomberg BNA about the Tel Aviv Stock Exchange's intention to reduce red tape and ease regulations to promote further growth in the number of new companies traded on the TASE.

Categories: Capital Markets | Financial Regulation | Tax

Israeli Tax Proposals for Blockchain, First Steps to Approval

Adv. Harel Perlmutter, the head of our Tax Department, was interviewed by Bloomberg BNA following the release of the Israel Tax Authority's new draft plan for taxing ICOs.

Categories: Blockchain | Capital Markets | Tax | Taxation of Cryptocurrencies

Everything You Need to Know about ICOs

Barnea hosted an ICOs and digital currencies event featuring a lecture on regulation opportunities and challenges. Adv. Harel Perlmutter also discussed the taxation of cryptographic coins and the Israel Tax Authority's position.

Categories: Blockchain | Capital Markets | Financial Regulation | International Taxation | Tax

Israel Arrests Two Individuals for Tax Evasion Linked to Panama Papers Leak

Following the Panama Papers leak, Israeli authorities have arrested two Israelis on suspicion of evading millions of shekels in tax payments by using companies registered in offshore tax havens. Adv. Harel Perlmutter, a partner and head of our Tax Department, commented to Bloomberg BNA that even though many Israelis were named in the leaked documents, most of them appear to have been using the offshore havens for reasons other than tax evasion.

Categories: International Taxation | Tax

Barnea Represents EXO Technologies in Acquisition by Lear

We represented Israeli startup EXO Technologies, a developer of GPS technology for autonomous and connected vehicle applications, in its acquisition by the US corporation Lear.

Categories: Corporate | High Tech | Investments | Mergers and Acquisitions | Start Ups

ITA Publishes New Draft Circular on Sale of Rights in Corporation

The Israel Tax Authority published a draft circular today about a sale of rights in a corporation when a portion of the consideration is paid to the seller at a future date.

Barnea Represents HP in Acquisition of Samsung Electronics Co.'s Printer Business

HP Inc., represented by Barnea, has completed its acquisition of Samsung Electronics Co., Ltd.’s printer business in a deal valued at USD 1.05 billion.

Categories: High Tech | Intellectual Property

Israeli Banks Told to Scale Back Overseas Activities After US Tax Evasion Scandal

Adv. Harel Perlmutter, a partner and head of Barnea’s Tax Department, was interviewed by Bloomberg BNA following the Bank of Israel’s call for Israeli banks to reassess their strategies for overseas operations. Harel noted that the Bank of Israel’s Supervisor of Banks aims to maintain a strong banking system, even if this means reducing banks’ profits from overseas activities.

Categories: Tax

Head of Deutsche Bank Israel Detained on Suspicion of VAT Offenses

Adv. Harel Perlmutter, head of our Tax Department, was interviewed by Tax Analysts following the arrest of the chief executive of Deutsche Bank’s Israeli operations on suspicion of violating VAT law. The Israel Tax Authority alleges that customers whose transactions Deutsche Bank reported as zero-rated on the grounds that they were conducted on behalf of foreign residents were, in fact, Israeli residents. Harel noted that determining whether someone qualifies as a foreign resident for tax purposes can be difficult.

Categories: Tax

Considering Bitcoin an Asset Could Set Back Usage in Israel

Adv. Harel Perlmutter, head of the Tax Department, was interviewed by Bitcoin.com regarding the Israel Tax Authority’s (ITA) draft on digital currencies. Harel commented that the draft circular is a declaration of intent from the ITA and at this stage no draft legislation has been published.

Categories: Start Ups | Tax

Doing Business in Israel – Practical Law

Doing business in Israel? A Q&A guide to doing business in Israel written by Barnea was published by Practical Law. The guide provides an overview of the legal system, foreign investment, regulation, and other issues pertaining to Israel.

Categories: Antitrust and Competition | Corporate | E-commerce | Employment | High Tech | Intellectual Property | Tax

AtoBe – Azrieli College of Engineering Startup Accelerator

Adv. Harel Perlmutter, head of the Tax Department, lectured today on the taxation of startups at the AtoBe – Azrieli College of Engineering Startup Accelerator.

Categories: Start Ups | Tax

International Taxation – New Draft Bill Will Require Foreign Companies to Report and Pay Tax in Israel

The Israel Tax Authority (“ITA”) is promoting legislation that will require foreign companies not subject to the Israeli tax regime today to report and even pay tax in Israel.

Seminar on New Multiple Housing Taxation Law

Barnea will host a morning seminar on February 14 on the new Multiple Housing Taxation Law. Adv. Maya Zisser, a partner in our Real Estate Department, will discuss who is subject to the new tax, the applicable rates, payment methods, exemptions, and credits. Adv. Harel Perlmutter of our Tax Department will discuss opportunities to reduce tax on rental income.

Categories: Real Estate Taxation | Tax

Israel Seeks Tax on Bitcoin, Virtual Currency Transactions

Adv. Harel Perlmutter, head of our Tax Department, was interview by Bloomberg on an Israel Tax Authority draft circular on the taxation of virtual currencies (bitcoins and the like). Harel commented that the draft imposes almost insurmountable restrictions on the use of virtual currencies in Israel, due to the liabilities and costs involved.

Categories: Internet | Tax | Taxation of Cryptocurrencies

Draft Circular on Taxation of Activities Using Virtual Currencies

The Israel Tax Authority published a draft  circular on taxation of virtual currencies (bitcoins and the like). According to the Draft, the ITA’s position is that virtual currencies should be deemed “assets” and not as currency or foreign currency or even as financial instruments.

“Wallet Companies” – Draft Tax Bill within the Scope of the Arrangements Law for 2017 - 2018

Recently, the Finance Committee concluded its deliberations regarding the imposition of tax legislation pertaining to “wallet companies” within the scope of the Arrangements Law for 2017 – 2018.

Expected Amendments to Tax Legislation in 2017

Adv. Harel Perlmutter, head of our Tax Department, interviewed by Ynet on the expected tax amendments going into effect in 2017.

Categories: Tax

Supreme Court Rejects Yaacov Peri’s Demand for Reduced Tax on Exercise of Options

This week, the Supreme Court rejected Yaakov Peri’s claim for a tax reduction on income from exercising options granted by the publicly traded company Lipman Electronic Engineering. Adv. Harel Perlmutter, Head of our Tax Department, told Globes that, during the period at issue, the corporate tax rate was 35%, while the capital gains tax rate for companies was 25%. Today, these rates are identical, so the distinction between the two types of tax no longer affects the applicable tax rate.

Categories: Tax

Seminar for Students From IDC Legal Clinic for Startups

Today, Barnea is hosting a seminar for students from the IDC Legal Clinic for Startups, covering founders’ agreements, employment law, taxation, privacy policies, entrepreneurship and more. This collaboration is part of the firm’s pro bono activities.

Categories: High Tech

EU: Apple Ordered to Pay Ireland EUR 13 Billion in Taxes

Adv. Harel Perlmutter was interviewed by leading newspapers about the European Commission’s order requiring Apple to pay EUR 13 billion (USD 14.5 billion) in unpaid taxes to Ireland. Harel noted that the landmark decision could expose Apple to billions of dollars in additional back-tax assessments.

Categories: Tax

Apple Must Pay EUR 13 Billion in Back Taxes to Ireland

Adv. Harel Perlmutter, the head of our Tax Department, was interviewed by several media outlets following the European Commission’s ruling that Apple had received unlawful tax benefits over two decades and was therefore required to pay EUR 13 billion in back taxes to Ireland.

Categories: Tax

Amendment of the Income Tax Ordinance – Information Exchange Between Tax Authorities

An amendment to the Income Tax Ordinance that was recently enacted obligates financial institutions to identify the residency and citizenship of their foreign account holders. The financial institutions are required to report the information to the Israel Tax Authority, so that the ITA can then relay that information to the relevant foreign tax authority. 

New Superior Court Ruling Regarding Taxation of Non Compete Benefits

After years of district courts issuing contradictory rulings, the Supreme Court recently resolved the ambiguity surrounding the classification of compensation in respect of non-competition covenants when employees leave employers.

Israel Tax Authority extends Voluntary Disclosure period

The Israeli Tax Authority (ITA) has announced this morning that the temporary Provision regarding the voluntary disclosure procedure which was supposed to expire today, has been extended until December 31st, 2016.

Israel Tax Authority Audits Short-Term Landlords

Adv. Harel Perlmutter, the head of our Tax Department, was interviewed by Globes following the Israel Tax Authority’s announcement of tax audits targeting landlords who offer short-term rentals. Harel explained that these landlords are liable for both income tax and VAT.

Categories: Real Estate | Tax

New Tax Ruling on the Subject of Holdbacks

The Israel Tax Authority published a tax ruling given by it recently that sheds light on the existing ambiguity when classifying proceeds from a sale of shares of a company

Tax treaty between Israel and Germany

On 21 August 2014 a new tax treaty between Israel and Germany was signed. The new treaty, which is based mainly on the model tax treaty of the OECD, introduces a number of favorable amendments (for the taxpayer) and improvements. 

 

 

Pending tax changes to short term apartment rents

The Israeli Tax Authority (ITA) recently announced, during a discussion of the parliamentary committee, that it is about to publish a tax circular in the matter of renting apartments for a short periods of time, including through Internet platforms such as Airbnb.

According to recently released data, In 2015 about 128,000 tourists visiting Israel rented apartments through Airbnb. This represents an increase of 45% compared to 2014, as well as an increase of 40% in the number of Israelis who offer their apartments for rent through Airbnb, which is now over 13,000.

Airbnb Users May Face a New Tax Reality

Airbnb has become a major player in the tourism market in recent years, with its user base growing by 40% over the past year. Thousands of Israelis rent out their apartments through the platform, earning the equivalent of a monthly salary. Until now, the Israel Tax Authority has not actively pursued enforcement of tax obligations on this income. Adv. Harel Perlmutter spoke to Ynet about new tax rules that could change this approach.

Categories: Tax

A precedential judgment in the matter of transfer pricing shuffles the cards as to granting options to employees

A judgment in the Contira case was handed down two weeks ago in the district court which dramatically changes the Cost Plus issues relevant to certain Israeli companies which provideservices to a foreign relatedcompany. The judgment impacts on the situation where the Israeli company’s employees are granted options in the framework of Section 102 of the Income Tax Ordinance (capital track).

Employee or Independent? How to Save Money as End of Tax Year Approaches

What can taxpayers do to take advantage of available tax breaks and allowances? Tax experts, including Adv. Harel Perlmutter, discuss these issues in an interview with Ynet.

Categories: Tax

Israel Signs OECD Automatic Tax Information Exchange Agreement

Israel has signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement (MCAA), which facilitates the automatic exchange of financial information. Israel’s participation brings the number of signatories to 91 and strengthens global efforts to combat tax evasion. Adv. Harel Perlmutter was interviewed by Bloomberg BNA about the agreement.

Categories: Tax

New law Memorandum: New tax incentives for public high-tech companies and investors

In order to promote the technology and biomedical industries and to restore the Israeli stock exchange to its position as an efficient and attractive arena for capital raising to companies, an ad hoc committee was formed to analyze feasible tax incentives.

Israel and Australia in Tax Treaty Talks

The Israel Tax Authority is negotiating a treaty with Australia to prevent double taxation. Adv. Harel Perlmutter, who specializes in international taxation, describes this development as “wonderful news,” noting that Israel and Australia enjoy excellent economic and political relations and that Israeli investment in Australia has tripled over the past three years. He explains that, until now, there have been no significant talks on a tax treaty between the two countries. The absence of a treaty can lead to double taxation, uncertainty and withholding tax complications in cross-border trade and business, particularly for Israeli companies seeking to operate and invest in Australia and Australian companies seeking to do the same in Israel.

Categories: Tax

Israel Tax Authority extends voluntary disclosure program

As expected, the Israeli Tax Authority has decided to extend the temporary order regarding anonymous Voluntary Disclosure.

The Israeli Tax Authority announced that the temporary order regarding voluntary disclosure, which was supposed to expire on September 6, 2015, has been extended.

The temporary order was published a year ago and was limited to one year. The regular procedure has been restricted until 31/12/2016.

In total, last year 3290 requests were submitted, about 60% of them anonymous. In light of this success, it was decided to extend the duration of the temporary order.

Additional information regarding the dates will be announced later.

Zero VAT on Medication Acquired for Clinical Trials in Israel

Amendments to Israel’s VAT legislation are expected to reduce the cost of clinical trials involving human participants, benefiting international companies that conduct trials in Israel. In an interview with Globes, Adv. Harel Perlmutter, who specializes in international taxation at Barnea, explained: "The amendments will have two main implications. First, an Israeli company acquiring medication from an overseas company will not have to pay VAT or customs duty in Israel, costs it would usually pass on to the overseas company. Second, the fees the Israeli company charges the overseas company for conducting the trials will be subject to VAT at a rate of zero percent."

Categories: Tax

Recent Tax Developments

Two pending amendments to Israeli tax legislation will, if adopted, permit the exchange of information about taxpayers in a multinational context. The passing of these amendments will also allow for implementation of multilateral agreements for ‘exchange of information’ regarding individuals and corporate tax payers.

Israel - Revision Voluntary Disclosure Tax Amnesty

The Israeli Tax Authorities have recently been very active in its efforts to detect tax evaders and unreported global income of Israeli tax residents. On the 7th of September a New Voluntary Disclosure Program, replacing the previous program, went into effect.

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