Tax in Israel
Goldfarb Seligman & Co.'s 'knowledge of Israeli and US tax laws is invaluable' for the department's corporate and high-net-worth client base and its 'most familiar relationships with the tax authorities' allow for 'a level of transparency in an otherwise overwhelming regulatory regime'. Given the firm's profile in Israel's M&A market - particularly the tech sector - the tax team has considerable experience handling the cross-border aspects of global multibillion-dollar corporate transactions, but also provides ongoing advice on disclosure, VAT issues, tax assessments, corporate structuring and tax disputes to many of the largest global technology companies operating in Israel. In the contentious space, Tal Atsmon is representing one of the world's largest beverage manufacturers in a tax dispute concerning certain payments with its domestic distributors; this case raises potentially systemic problems involving the taxation of the client's products across the globe. Also recommended is Yaron Sever, who, alongside Atsmon, handles remuneration matters for prominent Israeli corporates and advises individuals with a multi-jurisdictional financial presence on disclosure procedures in Israel.
Gornitzky & Co. provides individual and corporate tax structuring, regulatory advice and transactional support, and is involved in many of the country's most prominent tax disputes. In particular, the Israeli Tax Authority (ITA) has become increasingly interested in chasing large foreign companies for tax liabilities in Israel and, as a result, the team advises major multinationals on ITA tax assessments spurred by certain actions by the OECD. Daniel Paserman and Pinhas Rubin represented Flying Cargo in connection with a claim by the ITA concerning the legal treatment of 'goodwill' within a transaction for accounting and taxation purposes; at the time of writing, this matter is pending a Supreme Court appeal. Paserman is also acting for an international energy group in litigation regarding issues of distributable profits. The department continues to grow in terms of personnel and breadth of service, having recently established a sub-group focused on high-net-worth individuals. Gil Grady and Shlomo Aviad Zider are additional contacts in the department.
Herzog Fox & Neeman is considered by some multinational corporates to be 'the very best tax team in Israel', providing 'comparable service to what one would expect in New York, Boston or London'. Led by Meir Linzen, the team advises clients such as Aristocrat Leisure, Israel Electric Corporation and a host of global investment banks on complex cross-border corporate and securities transactions. Clients recommend Guy Katz and Yuval Navot for their expertise in cross-border tax structuring in connection with corporate transactions and reorganisations. The department also handles voluntary disclosures and offshore wealth management for hundreds of high-net-worth individuals, and is among the only domestic firms with a dedicated transfer-pricing group, which is headed by Eyal Bar-Zvi. Ofer Granot represents some of the world's largest companies operating in Israel in complex tax litigation, and Iris Weinberger heads the team's VAT and indirect tax sub-group.
Meitar Liquornik Geva Leshem Tal Law Offices
The tax lawyers at Meitar Liquornik Geva Leshem Tal Law Offices have 'strong technical tax skills', but perhaps more importantly 'the team also has an excellent of understanding of how the ITA will view a particular issue, which allows for practical solutions to complex problems'. As a complement to the firm's top-tier M&A practice, the tax team has 'a deep familiarity with foreign as well as domestic tax laws' and is thus adept at handling complex cross-border tax structures. In addition to the corporate transactional work, Shaul Grossman and Eldar Ben-Ruby provide comprehensive tax advice to high-net-worth individuals, trusts and estates, including disclosure advice in Israel and the US. Further, the team has experience with the tax aspects of fund formation, spanning venture capital, private equity, hedge and real estate funds. In the contentious space, Ben-Ruby represented a foreign-listed corporate in precedential negotiations with the ITA concerning certain regulations governing foreign corporations. Keren Shitrit and Meir Akunis are also recommended.
Shekel & Co. is one of Israel's oldest and largest tax boutiques and acts for international corporates as well as many of Israel's largest banks and public and private companies. The firm is well known in the telecoms and financial services sectors, and provides tax advice to clients such as Noble Energy and Delek Group in relation to all of the operating gas fields in Israel. Ofer Elboim is representing Isracard, Leumi Card and CAL - the three major Israeli credit card companies - in a VAT assessment concerning the clients' operations abroad, including commissions on forex transactions and payments made by Visa, MasterCard and Amex. Recently promoted senior partner Binyamin Tovi assists private equity funds with tax structuring issues associated with their M&A activity, and has also advised on the offshore tax structuring for overseas hedge fund activity. Yaniv Shekel is also recommended.
Ziv Sharon & Co. Law Office comprises 'professional and responsive' tax lawyers with backgrounds in prominent boutique tax firms and regulatory agencies. Ziv Sharon has considerable expertise in complex tax disputes, where he represents domestic and international corporates in negotiations before the ITA and at all levels of Israeli court. Of note, Sharon is acting for a client in relation to the tax implications of an arbitral proceeding with a foreign government concerning an incident with a gas pipeline. Sharon is also representing two hotel groups in a Supreme Court appeal regarding the correct treatment of foreign employees' levies. Orit Koch heads the real estate tax group and handles issues including urban renewal taxation for clients such as Africa Israel Investments, Azorim and Gindi Investments. Also recommended are Amit Glick, who acts for individuals and financial services companies in relation to VAT assessments, and Yoad Frenkel, who is a key contact for private client taxation and voluntary disclosure advice.
With nearly three decades of operation in Israel, Alter Attorneys at Law is a tax boutique specialising in international tax planning and tax disputes at the ITA and at all levels of Israeli courts. Anat Tenne and Amichai Pery are key figures at the firm, which handles tax issues such as transfer pricing, real estate and indirect taxation, immigration and employment taxation, trusts, and criminal tax issues.
Amit, Pollak, Matalon & Co. Advocates and Notary has experience in the tax aspects of cross-border investments, M&A transactions and major real estate projects, but the team stands out for its expertise in funds-related taxation. Indeed, Doron Levy is assisting Aura Investments with the establishment of a REIT, and Racheli Guz-Lavi provides ongoing tax advice to Israel Infrastructure Fund regarding the management of its investments and the structure of its various funds and co-investment vehicles. Levy, who heads the practice group, is also a name to note for high-value tax disputes; he is currently representing two trusts, with Israeli beneficiaries and international investment activities, in a dispute with the ITA concerning the taxability of certain activities abroad. Moreover, the team has been advising a number of private clients on the tax aspects of cryptocurrency holdings and investments.
The team at Eitan Mehulal Sadot, Advocates & Patent Attorneys represents high-net-worth individuals and large corporates in various matters before the tax authorities and also provides ongoing regulatory and commercial tax advice. In particular, the firm is noted for its customs practice and is duly engaged by a number of importers and exporters. Alice Abramovich represented Match Retail, the official importer in Israel for H&M, in a dispute with the customs authority regarding the payment of import taxes for royalty fees. Similarly, Abramovich acted for Fox Group in a dispute concerning import taxes on royalties relating to IP rights. Noa Lev Goldstein advised Poliran Profiles on its eligibility for tax benefits under the Encouragement of Capital Investments Law, and senior partner Yaron Mehulal is representing a company founder in a dispute concerning a payment he received in connection with the sale of his company to Elbit.
The tax team at Fischer Behar Chen Well Orion & Co is regularly involved in market-leading investment, real estate and M&A transactions, often with substantial cross-border elements. In addition, the department advises high-net-worth individuals on voluntary disclosure matters and trust planning, and also has experience in prominent tax disputes. Department head Anat Shavit has represented myriad domestic companies in contested tax assessments and is currently representing the Israeli subsidiary of a multinational online business in a dispute with the ITA regarding a VAT assessment, which raises novel questions of tax applied to certain types of products. Also of note, the department recently brought on senior associate Sagit Avital Assaf to expand its municipal taxation practice; Avital Assaf joined the team from the Tel Aviv Municipality. Clients include Mekorot (the Israeli national water company), Sky Private Equity Fund, and Colmobil.
Moshe Mizrachi, Noach, Kriegel & Co
Tax boutique Moshe Mizrachi, Noach, Kriegel & Co handles the full range of domestic and international tax issues and has an impressive client roster including large domestic financial services companies, public and private sector corporates, individuals and trust companies, industry associations, and global investment managers. Moshe Mizrachi represents The Israel Hedge Fund Association as well as a number of public individuals in matters before the ITA, and also represents a litany of companies in ITA negotiations concerning the Encouragement of Capital Investments Law. The team also acts for a number of energy and infrastructure companies and handles a variety of contentious and non-contentious tax matters for Edmond de Rothschild Group and Israel Discount Bank.
In terms of 'professionalism and client attention', S. Horowitz & Co is considered 'far superior to many of its competitors'. In addition to supporting the corporate group's cross-border transactional activity, the tax team handles taxation with regard to complex financial products and cryptocurrencies, and represents clients in disputes with the tax authorities, including criminal investigations initiated by the ITA. Department head Leor Nouman assisted a Chinese shipping company with negotiations concerning the taxation of Chinese workers in Israeli waters, and Ophir Kaplan has represented public companies such as Dubek in tax audits. Further, Nouman and Kaplan are representing Veolia Group in negotiations with the ITA regarding the sale of Veolia's entire Israeli business activity to a Luxembourg resident corporation. Additionally, the team advises families and individuals on voluntary disclosure proceedings. Zen Protocol, Bank Hapoalim, Perrigo Group and Booking.com are also among the department's clients.
Yaron-Eldar, Paller, Schwartz & Co. Law Offices
Yaron-Eldar, Paller, Schwartz & Co. Law Offices is a boutique tax firm that advises public and private companies, financial institutions and individuals on a full range of contentious and non-contentious tax matters. In particular, the firm has developed expertise in a number of niche areas, including cryptocurrency taxation, customs, and oil and gas taxation. Tali Yaron-Eldar ('an exceedingly professional advocate') has advised crypto-funds and Israeli investors on cross-border investment and ICO issues, especially where there are US tax concerns involved. The team also has expertise in nonprofit taxation, with Rany Schwartz assisting clients including The Jewish Agency with ongoing tax activity. In the contentious space, the team is representing The Restaurants Association and various other businesses in a claim concerning surcharges that were paid for the employment of asylum seekers and refugees. Gilad Ben-Ami is another key figure in the team.
Yigal Arnon & Co has 'a professional and service-oriented' tax team, handling high-end corporate transactions as well as tax litigation. 'A creative and sophisticated lawyer', Eran Lempert has 'a brilliant mind for tax' and provides ongoing operational, transactional and tax structuring advice to major multinationals, including Oracle Corporation, Medtronic, General Electric Lighting, and Microsoft Corporation. Of particular note, the team advised two financial institutions, as underwriters, on the cross-border tax aspects of the first-ever listing of shares in an Israeli company on the Stock Exchange of Hong Kong. Additionally, Lempert has been representing foreign companies that are increasingly finding themselves the targets of ITA audits and tax disputes. Ofir Levy is another contact in the practice group.
Yossi Elisha Calderon & Co.
Yossi Elisha Calderon & Co. has particular expertise in real estate taxation and, in that context, is engaged by real estate and construction companies, investment trusts, banks, infrastructure groups, and municipalities. Founder Yossi Elisha provides comprehensive tax advice to the Electra Group, Ashdod Port and Almog Yam Suf Real Estate. Elisha also advises Sella Capital Real Estate, a REIT, on the tax aspects arising from all of its ongoing projects and represents the client before the tax authorities. The team also advises The Institute of Tax Consultants in Israel on various regulatory and legislative issues. Another key contact is Benny Calderon, who has held positions with KPMG as well as the Israeli State Attorney for Taxation and Finance. Leumi Trust, Ampa Real Estate, and Bank Hapoalim are also among the team's clients.
Prof. Bein & Co. Law Office
Prof. Bein & Co. Law Office advises public, private and governmental companies on civil and criminal tax litigation, and also provides tax support for commercial transactions. Key figures in the team include former judge Dan Bein, Liora Bein-Alon, who has experience in criminal and civil law, and Yoav Bein, who has expertise in planning, development and property taxation.
Gross, Kleinhendler, Hodak, Halevy, Greenberg, Shenhav & Co.
Gross, Kleinhendler, Hodak, Halevy, Greenberg, Shenhav & Co. is applauded by international clients for its 'impressive' tax advice in cross-border M&A, corporate structuring and venture capital investment activity. The team advises Amazon on, among other things, the implementation of BEPS regulations in Israel, and has also advised on M&A transactions for clients such as Yahoo!. Elad Brauner in recognised for his 'responsiveness and constant availability'. In 2018, the department brought in a team from Shenhav & Co, which included tax specialists Moti Balilti and Oren Biran, the latter of whom now heads the tax practice. Biran has particular expertise in venture capital taxation and is engaged by investors such as Sequoia Capital Fund, Bessemer Venture Partners, TPY II Venture Capital, and Blumberg Capital. The team is also familiar with cryptocurrency taxation. Yaniv Erlich left the firm for a role in an investment management company.
Dr. M. Druker & Co. - Advocates & Notaries provides commercial tax advice across a range of industry sectors and represents clients before the ITA. Moshe Druker advises many of Israel's long-time diamond dealers on domestic income tax issues and on their activities through foreign trusts, and Ori Druker represented English conglomerate Howden Broking Group in negotiations for certain withholding tax exemptions. The team also advises Dan Gertler International Group on tax issues arising from its international investments. In the real estate sector, Eyal Tzidkiyahu acts for clients such as Gabso Group in relation to a range of investment and development activity, including tax issues arising from the client's Tama 38 projects.
Well known for its highly specialised investment funds work, Raveh Haber & Co. provides tax advice to fund managers in relation to fund structuring and investment activity. Gil Raveh, who leads the tax practice, also assists Israeli corporates with ongoing tax issues and has represented clients in disputes with the tax authorities. Raveh is representing multiple Israeli individuals in a dispute concerning income emanating from US LLCs with which the clients are associated; the case is pending a Supreme Court appeal. Additionally, the team assists families and high-net-worth individuals with a variety of tax matters, including voluntary disclosures.
S. Friedman & Co. Advocates & Notaries
The tax team at S. Friedman & Co. Advocates & Notaries has developed expertise in advising corporates in the shipping and education sectors on transactional and corporate structuring mandates. The department handles a wide range of tax issues for clients including MSC (Israel), Weizmann Institute of Science, Tel Aviv University, University of Haifa, and Ben Gurion University. In particular, Doron Schweppe assisted The Israel Shipyards with an opinion relating to shipping companies' transitioning into 'transparent companies'. The team also has experience in taxation arising from major real estate transactions and has represented companies and nonprofits before the tax authorities.
Shibolet & Co. with Raved, Magriso, Benkel & Co. fields 'a hardworking, resourceful tax team' recognised for its 'out-of-the-box thinking that enables solutions to international and Israeli tax issues'. Jointly headed by Miri Bickel and Benny Kalifi, the team has particular experience with taxation in the blockchain industry. Indeed, Bickel and Vered Meller, who recently joined the team from tax boutique U. Barzily Law Firm, have assisted a number of clients, including Bancor, with ICOs, the establishment of crypto-infrastructure and other blockchain commercial activities. Contentious work includes the team representing Malca Amit in an ITA assessment procedure. The group also provides disclosure advice to individuals and corporates. Poalim Capital Market, EY and Fahn Kanne Grant Thornton are among the tax department's key clients.
Clients of Tulchinsky Stern Marciano Cohen Levitski & Co. consider the legal team to be 'an integral part of their internal team'. The team counsels clients such as Teva Pharmaceutical Industries and Jerusalem Venture Partners on all aspects of contentious and non-contentious tax. The key contact in the tax team is Isaac Marciano, who handles the tax aspects multibillion-dollar cross-border M&A and has been involved in tax disputes worth billions of shekels. Also recommended is senior associate Elad Mirvis, who has experience in tax litigation. Other key clients include The Caesarea Edmond Benjamin de Rothschild Foundation and Orbotech.
Yair Benjamini Law Offices has 'noted expertise in Israeli and US tax laws' and is recognised throughout the market for its capabilities in tax litigation. Yair Benjamini is representing a global media group in a dispute with the ITA concerning its global activity and is also assisting the subsidiary of a listed Spanish company with negotiations surrounding a long-running tax audit. The team has also been engaged by domestic and multinational law firms to assist with the tax aspects of high-value cross-border M&A and corporate structuring. In one example, the group acted for Hewlett Packard Enterprise in relation to its spin-off from Hewlett Packard. The department also provides tax advice to trusts and private wealth vehicles concerning their investment activities abroad. Further, Sagiv Ron specialises in real estate taxation and has experience with the taxation of large urban renewal projects. Shahar Strauss joined the firm from top-ranked Ziv Sharon & Co. Law Office, and Doron Elmekiesse joined from the Tel Aviv tax authority. Associate Amir Cooper is also recommended.
Bracha & Co is a boutique firm that is led by Itay Bracha, who specialises in taxation and anti-money laundering. Bracha handles tax planning, voluntary disclosures, real estate taxation, and tax disputes for Israeli and foreign individuals. Bracha has assisted with voluntary disclosure mandates in Israel, Europe, and North America.
The team at Pearl Cohen Zedek Latzer Baratz has 'a unique understanding of the intersection of domestic and international tax matters' and the firm has the global presence to field real experts in US, European and Israeli tax law. Henriette Fuchs chairs the Israel tax team and provides comprehensive tax advice to clients including BIG Shopping Centers. Fuchs is also co-representing a client in tax litigation questioning the relevant legislation for the taxation of the client's activities beyond Israel's territorial waters. Based in the firm's New York office, Oz Halabi chair's the US tax team and regularly works alongside the Tel Aviv hi-tech practice in relation to the taxation of venture capital funds and cross-border investors.
Rosenberg Abramovich Schneller, Advocates has particular expertise in estates, trusts and international wealth planning. In this regard, the team is engaged by some of Israel's wealthiest families and individuals and also handles Israel-facing tax issues for the private clients of some of the world's largest law firms as well as for clients of international boutique private client law firms. The group is jointly managed by Avi Abramovich and Ari Rosenberg, and George Rosenberg heads the international taxation team. Based in the firm's Zurich office, Inbal Faibish Wassmer lends support to the firm's international reach and eases access to an important market for private wealth clients.
Acting for Israeli individuals and a host of domestic and listed foreign companies, Zysman, Aharoni, Gayer & Co (ZAG-S&W) provides 'client-focused advice' on transactional and ongoing taxation issues. The team provides a range of operational and regulatory advice to foreign companies and Israeli subsidiaries. Headed by Boaz Feinberg, the team also represents corporates in tax assessment procedures and has acted for clients in civil and criminal tax disputes. The department is also engaged by nonprofits.