Client updates /  Tax Ruling

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

A recent district court ruling broadened the interpretation of the statutory provisions governing exemptions from land appreciation tax and ruled that transfers of shares of a real estate association as a gift between siblings are exempt from capital gains tax even if the shares were not direct gifts from the parents but originated from land received as a gift from them. The court also prescribed several important procedural rules to improve the protection of taxpayers’ rights vis-à-vis the Israel Tax Authority (ITA).

Israeli tax ruling on the question: The Committee deliberated the North Mall appeal and ruled recently that a “partial cancellation” of a real estate sale transaction is, in fact, a new transaction subject to additional tax

Under what circumstances will a court rule a transaction is an artificial transaction for tax purposes? In the case of Shalam Packaging Products Group, the district court rejected the tax assessor’s claims and ruled that the group’s restructuring was a legitimate business action and that the group did not execute the restructuring merely to reduce tax liabilities.

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