STL’s extensive knowledge of the private fund and venture capital industry in Israel, along with our international tax expertise, enables us to guide clients through every stage of the fund lifecycle. We cover fund formation, including the securing of income tax and VAT rulings; economic arrangements for sponsors; downstream M&A transactions, fund restructurings, and tax planning upon termination.
Services
Tax Structuring: We offer advice on the optimal tax structure for the main and parallel funds. Among other issues, we address the tax implications for institutional investors, including the provision of legal opinions to support available exemptions (such as under Section 9(2) of the Israeli Income Tax Ordinance) and the personal tax implications for principals, including those related to carried interest.
Tax Rulings and Opinions: We secure tax rulings or opinions to clarify tax treatment for the fund investors and ensure compliance.
Ongoing Tax Advice: Our tax guidance covers every stage of the fund lifecycle. We advise on the tax implications of different investment strategies and transactions; on cross-border tax issues, including questions of withholding tax; on the tax implications of fund distributions and carried interest arrangements; on tax-efficient exit strategies; and on the structuring of liquidity events.