Insights & News / Itiel Shloush

November 4, 2026

Barnea Represents Affle 3i Ltd in ILS 420 Million Acquisition of Perion Network Ltd

Our firm represented Affle, a publicly traded Indian adtech company, in its USD 420 million acquisition of Perion through a reverse triangular merger. Adv. Misha Gitterman, Adv. Mayer Winkler, Adv. Shuki Sedley, and Adv. Daniel Adler represented Affle in the transaction, with additional support from Adv. Tamar Greenstein and Adv. Diana Sattarov Kofman. Our firm also advised on the tax, employment, and capital markets aspects of the transaction. The tax team was led by Adv. Hanna Daher, Adv. Alon Davidovich, and Adv. Itiel Shloush; the employment team by Adv. Netta Bromberg and Adv. Erica Barmack; and the capital markets team by Adv. Batel Torangi and Adv. Amiel Leibovitch.

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Categories: Corporate | Mergers and Acquisitions

March 17, 2026

OECD Updates Tax Treaty Model – Implications for Remote International Work

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.

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February 5, 2026

Approval of Minimum Corporate Tax on Multinational Groups Law: Israel Joins the New Global Standard

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.

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December 10, 2025

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.

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July 27, 2025

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

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May 13, 2024

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.

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Insights & News / Itiel Shloush