FOR INTERNATIONAL LAW FIRMS, MULTINATIONAL GROUPS, TRUSTEES, FAMILY OFFICES AND INSURERS
Israeli tax counsel to international advisers
We advise foreign law firms, trust companies, family offices and insurers on the Israeli tax aspects of their clients’ matters. The client relationship remains with you.
When Israel becomes relevant
Israeli tax exposure often arises before anyone recognizes it.
A beneficiary of a long-standing trust becomes an Israeli tax resident. A client returns to Israel after years abroad, or a family’s ten-year tax exemption as new immigrants approaches its end. An acquisition target turns out to have employees, equity awards or a branch in Israel, or the sale of its shares raises Israeli withholding tax issues.
The implications can be difficult to assess from outside Israel. Israeli tax residence rules, the taxation of trusts and withholding tax requirements each have distinctive features that may be unfamiliar to advisers in other jurisdictions. Some of the most valuable planning opportunities are available only before the relevant event occurs: a distribution, a relocation or the closing of a transaction.
Matters we advise on
01
Private wealth
Foreign trusts with Israeli-resident settlors or beneficiaries, including classification, distributions and historic reporting.
Relocation to and from Israel, residence and treaty positions, and planning ahead of the expiry of the ten-year exemption for new immigrants and senior returning residents.
Succession and intergenerational planning for internationally mobile families.
02
Transactions and investment
The Israeli tax dimension of acquisitions, disposals and reorganisations, including Israeli employee equity under Section 102 and withholding on consideration paid to sellers.
Investment, fund and co-investment structures with Israeli investors, managers or targets, including carried interest.
Recovery of Israeli tax withheld from treaty-protected foreign residents.
03
Tax risk insurance
We advise underwriters on Israeli tax risks proposed for insurance: assessing the likelihood and scale of exposure, reviewing policy wording, and supporting insurers where an insured position is later examined by the Israel Tax Authority.
Representative matters
- Advised on the Israeli tax aspects of a multinational group’s reorganization and exit from Israel, including the transfer of a long-established branch with over 100 employees to a new Israeli company ahead of its sale.
- Acted on the Israeli tax aspects of a European technology company’s acquisition of a US company with Israeli employees, including Section 102 equity awards, withholding and paying-agent arrangements.
- Advised London insurers on the Israeli tax risk underlying tax insurance placements and supported them through a subsequent Israeli tax audit.
- Advised the senior managers of an Israeli fund on structuring their carried interest to support capital gains treatment.
- Restructured a multinational family’s holdings and trusts ahead of the expiry of the parents’ ten-year exemption as new immigrants, working with advisers in different jurisdictions.
- Advised an Israeli resident holding assets in Israel, the United States and Canada on regularizing the holding structure, weighing Israeli relief for closely held companies against US estate tax and Canadian deemed-disposition rules.
- Advised two founders on the exit of their investors, structured together with the founders’ relocation from Israel.
Client names are withheld.
Where personal tax and transaction tax meet
Founder exits, family-owned sellers and investors relocating around a liquidity event, where the structure of the transaction and the personal tax position of its owners have to be planned together.
Before the Israel Tax Authority
Where certainty matters, we seek advance tax rulings and represent clients in audits, assessments and negotiations with the Israel Tax Authority. Members of our team previously served in the Authority’s professional division.
How we work
Anat Shavit leads every matter personally. We work within the scope you define: a formal opinion, a structuring memorandum or a view on a specific question.
Our advice is limited to Israeli tax law. Where a matter extends further, we coordinate with your other advisers; recent matters have involved counsel in the United States, Canada, the United Kingdom, France, Switzerland and the Netherlands.
Anat Shavit
Founder
More than thirty years in Israeli and international tax. Before founding Shavit Tax Lawyers, she headed the tax practice at FBC (Fischer Behar Chen) for seventeen years. Ranked by Chambers Global, Chambers High Net Worth and The Legal 500.
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