Practices

Income Tax

Our firm specializes in various aspects of income tax, including individual taxation, corporate and partnership taxation, mergers and splits, capital gains, offsetting losses, options and capital instruments for employees.

Our firm provides, inter alia, representation before the tax authorities regarding all aspects of income tax; Seeing clients and accountants through all tax aspects of ongoing business and their conduct with the tax authorities; We give tax advice based on our extensive knowledge of tax law, general law, relevant case law and our acquaintance with the Tax Authorities; Tax planning in unique or complex tax events; Finding creative solutions to reduce the tax rate; Tailoring the tax plan to the client’s needs while avoiding “tax accidents”.

The firm’s services are based on an unconventional way of thinking combined with our vast accumulated knowledge of tax law, general law, relevant case law and a deep understanding of the way the Tax Authorities operate.

VAT

Our firm specializes in VAT and how it interacts with other tax laws and regulations. Our firm has particular expertise in VAT aspects of international transactions between Israeli and foreign customers, including applying a zero VAT tax rate. We provide our clients with ongoing legal advice regarding VAT liability, prepare professional opinions and applications for tax rulings and represent our clients vis-a-vis the VAT authorities.

International Taxation

Our firm provides a variety of services to its clients from Israel and abroad in all matters relating to consulting, accompanying and constructing tax structures and creative tax planning to minimize global tax liability, while adapting the plan and the client’s exposure to his needs. Inter alia, we provide legal advice and accompaniment regarding the following matters:

• Seeing through investment deals in Israel and abroad regarding taxation for both Israeli and foreign clients in order to maximize tax benefits and minimize tax liability in Israel.
• Tax planning, setting up multinational tax structures and operating them including in offshore regimes, in order to minimize international tax liability.
• Providing guidelines and opinions in order to minimize the exposure of foreign entities to classification as Israeli residents for tax purposes due to the “control and management” issue and the existence of a permanent establishment in Israel.
• Providing Tax plans and providing guidelines and opinions in order to minimize the exposure of foreign entities to classification as a Controlled Foreign Corporation (CFC) and as a Professional Foreign Company (PFC).
• Providing legal advice regarding registration and reporting liabilities of foreign entities in Israel for tax withholding and VAT purposes.
• Providing legal advice regarding the interpretation of the relevant tax conventions.
• Providing legal advice in order to maximize the use of foreign tax credits against tax liabilities in Israel.

Returning Residents and Relocation:

Our firm provides tax advice for clients in the process of relocation to and from Israel while planning the process in an optimal manner and broaching all relevant issues including the obligation to report to the tax authorities, tax benefits, exit taxes and so forth. In addition, our firm provides opinions regarding the question of residency and priming businesses to maximize tax benefits for returning residents and new immigrants.

Real Estate Taxation

Our firm provides legal advice and accompaniment regarding the taxes that apply to real estate transactions, including the sale of residential dwellings and obtaining an exemption from land appreciation tax, purchase tax reliefs, Tama 38 and urban renewal, preparing complex tax calculations, real estate corporations and their dissolution, transferring real estate assets when dividing an estate and dissolution of a joint ownership on land.  Our firm has particular expertise in real estate transactions in the kibbutz sector and the tax aspects that apply when allocating dwellings to the members. Moreover, our firm specializes in representation before the tax authorities in assessment proceedings and appealing and representing before appellate committees and the supreme court.

Assessment Hearings and Litigation:

Our firm believes in conducting a dialogue with the tax authorities while reaching agreements to the client’s satisfaction. However, our firm has vast experience in representing assessees before the courts, including complex cases before the Supreme Court, and specializes in tax laws, court procedures and the relevant rules of administrative law.

Our extensive experience allows us to handle complex cases with intricate accounting, calculative and legal aspects while striving for the best solution for the client according to his wishes.

Encouragement Laws and Tax Benefits:

Our firm provides close support for clients who wish to receive tax benefits as per the encouragement laws and operates vis-a-vis the Tax Authority, the Chief Scientist and the Ministry of Industry and Trade in order to receive these benefits. Our firm specializes in receiving pre-rulings from the Tax Authority regarding the client’s status in meeting the prerequisites for receiving the tax benefit.