EXPERTISE

For Individuals

Residency & “center of life” analysis

We provide comprehensive residency assessments under Israeli law, including:
Evaluation of “center of life” indicators (family, economic, and social ties)
Analysis of days-based residency tests and tie-breaker rules under tax treaties
Strategic planning to support or dispute residency classification
This service ensures clarity and mitigates risk in situations involving relocation, dual residency, or cross-border activity

10-Year Exemption Planning (Foreign Income) & Reporting Obligations

We assist new immigrants and returning residents in structuring their global affairs to maximize eligibility for the 10-year exemption regime. Our services include:

Mapping foreign income streams and assets
Assessing eligibility under the law and recent case-law interpretations
Designing compliant reporting frameworks while leveraging available reliefs
Advising on timing, documentation, and risk management
Our guidance ensures that clients can benefit from the exemption regime while maintaining full compliance

For Companies

Cross-Border Structuring, Financing, IP & Holding Entities

We work with privately held companies to design efficient international structures that support global operations, including:

Establishment and review of holding companies, financing vehicles, and operational entities
Tax-efficient structuring of shareholder loans, intercompany agreements, and profit allocation
IP structuring for development, ownership, and licensing across jurisdictions
Ensuring alignment with Israeli regulations and foreign tax regimes

Israel CFC/FVC Rules Review and Mitigation

We provide in-depth analysis of Israel’s anti-deferral regimes, including:

Assessment of whether a foreign company qualifies as a CFC or FVC under Israeli law
Shareholder exposure mapping and tax impact analysis
Strategies to mitigate or avoid unintended CFC/FVC classifications
Ongoing compliance monitoring for companies with international structures

Pre-Immigration Asset Review, Trusts, and Entry/Exit Tax Coordination

We offer detailed planning for clients relocating to or from Israel, including:

Reviewing global asset portfolios to identify tax exposures and opportunities
Structuring trusts and family arrangements in line with Israeli tax rules
Coordinating exit tax or entry tax implications to avoid double taxation
Preparing a long-term cross-border strategy that anticipates future life events

Treaty Relief, Withholding Tax (WHT), Certificates & Rulings

We assist companies with navigating international tax treaties and Israeli withholding obligations by offering:

Treaty relief planning to reduce or eliminate double taxation
Assistance with securing residency certificates and WHT reduction/exemption approvals
Preparation and negotiation of tax rulings with Israeli authorities
Guidance on inbound and outbound dividends, interest, royalties, and service fees