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Insights & News / Harel Perlmutter

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

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

The Israeli food producer Osem is continuing to transfer intellectual property rights to Nestle

Yuval Lazi and 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 the Israeli high-tech employment market and included diverse lectures on such topics as non-competition clauses in employment agreements, the workforce as a critical element in the workplace, and more.

Among the speakers at the conference were Micky Barnea, our firm’s managing partner; Nani Maoz, the founder, chairman, and CEO of Everest; and firm lawyers Harel Perlmutter, Netta Bromberg, Inbar Gorelick, and Amos E. Rosenzweig.


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

Tax Guide for New Immigrants – Harel Perlmutter Article for MIGNEWS

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

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

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 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, 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. Harel Perlmutter, head of our firm's Tax Department, talks with Guy Lieberman about tax hitches and opportunities in an interview also published on Globes.


Categories: Real Estate | Real Estate Taxation | Tax

No Freebies? 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. 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

Harel Perlmutter Featured on “Tzeva Hakesef” Radio Program

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: Harel Perlmutter Op-Ed in Mako

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

Categories: Tax

Taxes: Harel Perlmutter Lectures at Tel Aviv University

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 Samuel Henry Samuel and Harel Perlmutter discussed various aspects of entering the Israeli market.

Categories: High Tech

Oligarchs, Sanctions, and Money Transfers - Harel Perlmutter in the Sunday Times

Is Israel a tax haven for Russian billionaires? Our firm's 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 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 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.

Simon Jaffa, Ariella Dreyfuss, Harel Perlmutter, and Fadi Atallah from our office 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, Harel Perlmutter, the head of our firm’s Tax Department, provides valuable advice on the subject.

Categories: Tax

Representing Sephira in Sale of Shares to DL Software Group

Barnea represented the French and Israeli group of companies Sephira, a leader in software solutions for healthcare professionals, in the sale of its holdings to the DL Software Group, which was recently acquired by the American PE fund TA Associates.

The transaction was led by Samuel Henry Samuel, and Avihay Asulin. Netta Bromberg provided representation in all labor law matters, and Harel Perlmutter and Nir Ziman advised on all tax issues.

Categories: Corporate | Investments | 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

“Pandora Papers” Scandal: N12 Interview with Harel Perlmutter

The “Pandora Papers” scandal, revealed yesterday, shines a spotlight on the world of tax havens.

Firm partner and Tax Department head Harel Perlmutter 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 non-profit 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. Our firm's  Zohar Lande, Eyal Nachshon, Harel Perlmutter, Nir Ziman, and Omer Keydar represented the Azrieli Foundation throughout the proceedings, which lasted about five years.

Categories: Litigation | NPO | Tax

Tax Facts on Renting Out Apartments in Israel and Abroad – Podcast with Firm Partner Harel Perlmutter on Calcalist Website

Are you renting out an apartment? It is important to be aware of the existing rental income tax tracks, if there is a difference between the taxation of short-term rental apartments and long-term rental apartments, and the rules on renting out apartments abroad.


Adv. Harel Perlmutter, partner and head of our firm's Tax Department, addresses all these questions in a comprehensive podcast on the taxation of renting out apartments 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%.

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. We also lectured on the employee hiring process, and on 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 taxation field, Harel Perlmutter was interviewed by Bizportal on the issue and its implications.

Categories: Tax

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

Harel Perlmutter, the head of our Tax Department, has published an op-ed in Globes on the importance of recognizing childcare expenses for tax purposes, particularly now during the coronavirus period.

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 Representing Original Shareholders the Topaz Family in Sale of Holdings in Keystone Group

About a year and a half after the investment fund Accelmed, which is managed by Uri Geiger, announced the merger of the company it controls, American Keystone Group, with the Israeli Paltop company, controlled by Shmuel Topaz, it is now acquiring the entire holdings in Paltop for NIS 100 million. This ends the conflict between the investor groups of Paltop and Accelmed. Advs. Daniel Lorber, Netta Bromberg, and Harel Perlmutter  represented the Topaz family and the Paltop investors.


Categories: Corporate

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 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 Represented 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

All the Tax Considerations Returning Residents Need to Know

Adv. Harel Perlmutter will lecture on a webinar held by Toshav Chozer NPO. The webinar is focused on the tax considerations returning residents to Israel should be familiar with. The decision to return to Israel, normally a very complicated one, has taken on new meaning with the impact of the coronavirus. Harel will discuss all tax rights.


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, IP, etc.

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

Harel Perlmutter was interviewed by Tax Notes International following criticism that the reliefs the Israel Tax Authority issued for taxpayers in light of the coronavirus pandemic are insufficient.

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 today a meetup of the Florida-Israel Business Accelerator. Yuval Lazi and Harel Perlmutter met with the participating startups and discussed the challenges and opportunities of working with the US.

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 Ecommerce

We hosted today a meetup for female entrepreneurs in the ecommerce field. Harel Perlmutter and Anat Even-Chen lectured to the participants on the taxation and regulatory issues that could affect them.

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 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

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 Represented Bridgepoint in the Acquisition of Qualitest

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

Categories: High Tech | Investments | Tax

Bar Refaeli to Pay Taxes on Millions Earned Abroad

Following the ruling that Bar Refaeli must pay NIS 16 million in income tax, Adv. Harel Perlmutter, the head of our tax team, was interviewed by a popular radio program on 103FM.

The Central District Court in Lod rejected yesterday the supermodel's appeal, which was filed following an Israel Tax Authority order that she pay taxes in Israel on millions of dollars in income earned abroad.
Refaeli claimed that during the relevant years she spent only six months in Israel, and as a foreign resident, she did not owe any money to the tax authorities.

Harel Perlmutter explained the definition of a country of residence, as the trial revolved around the question of whether Refaeli was domiciled in Israel in 2009 and 2010. He also clarified the difference between the civil case and 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 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.

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 on 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, 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: Itay Gura lectured on founders' agreements, Daniel Lorber on intellectual property, and Harel Perlmutter on the tax issues of startups.

A 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 represented Senetas Corporation Ltd.

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 Tax Department, was interviewed by Bloomberg BNA on the decision of Amazon Web Services’ 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 NIS 156m from eBay

Adv. Harel Perlmutter was interviewed by Bloomberg BNA, following the reveal of eBay Inc. that the Israel Tax Authority is demanding NIS 156.6 million in additional taxes from the company 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 Represented 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, Head of our Tax Department, was interviewed by Bloomberg BNA following a new labor court ruling. The ruling 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

Harel Perlmutter, 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 Harel Perlmutter

Harel Perlmutter, Head of our Tax Department, was interviewed by Bloomberg BNA in the wake of new publicity surrounding the Milchan Law. The law in question 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

Dr. Zvi Gabbay, Head of our Capital Markets Department, and Adv. Harel Perlmutter, Head of our Tax Department, were interviewed by Bloomberg BNA regarding the Tel Aviv Stock Exchange's intention to reduce red tape and ease regulations in order to further continue the growth in the number of new companies being traded on 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 is hosting an ICOs and digital currencies event today. Dr. Zvi Gabbay will lecture on regulation opportunities and challenges, while Harel Perlmutter will discuss the taxation of cryptographic coins and the Tax Authority's position.

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

Israel Arrests Two 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. Harel Perlmutter, a partner and head of Barnea's 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 & Co. Represented EXO Technologies in Acquisition by Lear

Barnea represented Israeli startup EXO Technologies, a developer of GPS technology for autonomous and connected vehicle applications, in its acquisition by the American 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 & Co. represents HP in its acquisition of Samsung Electronics Co. Printer Business

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

Categories: High Tech | Intellectual Property

Israeli Banks Told to Scale Back Overseas Activities after U.S. Tax Evasion Scandal

Adv. Harel Perlmutter, partner and head of Barnea's Tax Department, was interviewed by Bloomberg BNA, following the Bank of Israel's call on Israeli banks to redefine their strategies for overseas operations. Harel noted that the Supervisor of Banks at the Bank of Israel wants to keep the bank system strong even if it means cutting part of the banks' profits deriving from activity outside of Israel.

Categories: Tax

Head of Deutsche Bank Israel Detained on Suspicion of VAT Offenses

Adv. Harel Perlmutter, Head of the Tax department at Barnea, was interviewed by Tax Analysts following the arrest of the chief executive of Deutsche Bank's operation in Israel on suspicion of violating VAT law. The Israel Tax Authority claims that the customers, in respect of whom Deutsche Bank reported its transactions as being zero rated, allegedly because they were conducted on behalf of “foreign residents”, were actually Israeli residents. Harel commented that it is often difficult to determine whether someone is a foreign tax resident.

Categories: Tax

Considering Bitcoin an Asset Could Set Back Usage in Israel

Adv. Harel Perlmutter, Head of the Tax Department at Barnea, was interviewed by Bitcoin.com regarding the Israeli 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 in the Practical Law website. The guide gives 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 at Barnea, lectured today on 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 the New Multiple Housing Taxation Law

Barnea is conducting on February 14th a morning seminar on the new Multiple Housing Taxation Law. Adv. Maya Zisser, Partner at the Real-Estate Department will lecture on the new tax - to whom does it apply, the tax rate, payment methods, exemptions and credits. Adv. Harel Perlmutter from the Tax Department will lecture on tax saving opportunities in respect of rental income. 

Categories: Real Estate Taxation | Tax

Israel Seeks Tax on Bitcoin, Virtual Currency Transactions

Adv. Harel Perlmutter, Head of the Tax Department at Barnea, was interview by Bloomberg regarding a draft circular of the Israel Tax Authority on 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 the Tax Department at Barnea was interviewed by Ynet regarding the expected tax amendments going into effect in 2017.

Categories: Tax

The Supreme Court Rejected Yaacov Peri’s demand for Reduction From tax payable on an Exercise of Options

This week the Supreme Court rejected Yaakov Peri's demand for a tax reduction from the tax authorities from an exercise of options received by the public company, Lipman Electronic Engineering. Adv. Harel Perlmutter, Head of the Tax Department at Barnea was interviewed by Globes and noted that during the period in which the controversy arose, there was a difference between corporate tax (35%) and capital gains tax (25%) for companies. Today, when the tax rates are identical, there are no implications arising from the nature of the tax imposed on the taxpayer.

Categories: Tax

Seminar for Students From the IDC Legal Clinic for Start-Ups

Barnea is hosting today a seminar for students from the IDC Legal Clinic for Start-Ups on various issues including founding agreement, labor law and tax issues, privacy policy, entrepreneurship and more. The cooperation is part of the firm's pro bono activities.

Categories: High Tech

EU: Apple ordered to Pay Ireland 13 Billion Euros in Taxes

Harel Perlmutter was interviewed yesterday by leading newspapers regarding the EU Commission’s order against Apple to pay 13 billion Euros ($14.5 billion) to Ireland in respect of unpaid taxes. According to Perlmutter, Apple could be hit with billions of dollars in assessments for back taxes after this landmark decision.

Categories: Tax

Apple Must Pay 13 Billion Euros in Back Taxes to Ireland

Adv. Harel Perlmutter, Head of the Tax Department at Barnea, was interviewed by several media following the European Union's ruling that Apple was given illegal tax benefits over two decades, therefore will need to pay 13 billion Euros in back taxes in 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.

The Israel Tax Authority conducted an audit of short term landlords

Adv. Harel Perlmutter, Head of the Tax department at Barnea, was interviewed by Globes following the announcement by the Israel Tax Authority regarding tax audits of short term landlords. Harel explained that these landlords are liable not only for the payment of income tax, but also for the payment of 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

In the last few years the Airbnb platform has become a significant player in the tourist market, with a user base growing at 40% at the last year. Thousands of Israelis rent out their apartments through Airbnb and earned an amount equivalent to a monthly salary. The ITA has (until now) not been proactive in enforcing the taxability of such income. 

Adv. Harel Perlmutter was interviewed for the Ynet website and spoke about the new tax rules that may change this trend.

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? Ways to save money at the fast approaching end of the tax year, 2015.

What can the taxpayer do to take advantage of available tax breaks and allowances?

Tax experts, including adv. Harel Perlmutter, discuss these issues on Ynet.

Categories: Tax

Israel signs OECD Automatic Tax Information Exchange Agreement

Israel signed the Organization for Economic Cooperation and Development’s Multilateral Competent Authority Agreement (MCAA) to facilitate the automatic exchange of financial information, boosting the number of signatories to 91 and enhancing the global efforts against tax evasion, the OECD announced. 

Harel Perlmutter was interviewed by Bloomberg BNA about this 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 for prevention of double taxation with Australia.

Adv. Harel Perlmutter, who specializes in international taxation at the Barnea law firm, believes this progress is "wonderful news. Israel and Australia have excellent economic and political relations, and Israeli investment in Australia has tripled over the past three years. At the same time, no significant talks have yet taken place on a tax treaty between the countries. This lack of a treaty sometimes brings about situations of double taxation and uncertainty, together with problems of withholding tax in trade and business, especially among Israeli companies seeking to operate and invest in Australia, and vice versa."

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

The new VAT amendments will lower the cost of clinical trials on humans in Israel. The amendment to the VAT legislation is expected to benefit international companies which conduct clinical trials in Israel.

Adv. Harel Perlmutter, who specializes in international taxation at Barnea & Co., was interviewed to Globes and stated that: "the new amendments will have two major implications – Firstly when the Israeli company acquires the medication from an overseas company, the Israeli company will not have to pay VAT or Customs Duty in Israel (the Israeli company will usually pass on these costs to the overseas company). Secondly, when the Israeli company charges fees for its services to the overseas company for doing the trials, the Israeli company will charge VAT at zero per cent."

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.